ML20198K661

Safety Evaluation Supporting Amend 120 to License DPR-6

ML20198K661
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Site:	Big Rock Point File:Consumers Energy icon.png
Issue date:	12/24/1998
From:	NRC (Affiliation Not Assigned)
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ML20198K657	List: ML20198K655 ML20198K658 ML20198K661
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NUDOCS 9812310124
Download: ML20198K661 (62)

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[ t UNITED STATES j ,j NUCLEAR REGULATORY COMMISSION o g WASHINGTON, D.C. 20555-4001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO.120 TO FACILITY OPERATING LICENSE NO. DPR-6 CONSUMERS ENERGY COMPANY BIG ROCK POINT PLANT DOCKET NO. 50-155

1.0 INTRODUCTION

By letter dated September 19,1997, as supplemented by letters dated October 10 and November 12,1997, and June 5, July 21 and 27, October 14, November 25, and December 21,1998, the Consumers Energy Company (licensee or Consumers) submitted a request for amendment of the Big Rock Point (BRP) Facility Operating License No.

DPR-6. The requested amendment would change portions of the existing BRP Facility Operating License and many of the requirements in its Appendix A, Technical Specifications (TS). Consumers developed its proposed license changes and revised TSs, entitled Defueled Technical Specifications (DTS), to reflect the permanently shutdown and defueled status of the BRP facility. Changes are proposed in the license, definitions, limiting conditions for operation (LCO), surveillance, and administrative control sections.

Further, as described in its letters dated November 25 and December 21,1998, Consumers requested withdrawal of certain portions of its proposed licence and TS changes it had requested in previous submittals.

The information and changes provided in the October 10 and November 12,1997,and June 5, July 21 and 27, October 14, November 25, December 21,1998, submittals did not change the staff's proposed no significant hazards consideration determination published in the Federal Reaister on December 3, N997 (62 FR 63974).

2.0 DISCUSSION The BRP facility is a 240 MWt boiling-water reactor (BWR) plant located in Charlevoix County on the northern shore of the State of Michigan's lower peninsula. The facility was operated by and continues to be maintained by Consumers. BRP achieved initial criticality on September 27,1962, and began commercial operation on March 29,1963, with a full-term operating license issued on May 1,1964. Following approximately 33 years of power operation, the reactor was permanently shut down on August 30,1997, for economic reasons. On September 20,1997, the fuel was permanently removed from the reactor vcssel and placed in the spent fuel pool (SFP) for interim storage. The licensee 9812310124 981224 PDR ADOCK0500g5 W

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I submitted written certification to the Commission on June 26,1997, that it had decided l

to permanently cease operation at BRP and on September 23,1997, that all nuclear fuel l

had been permanently removed from the reactor vessel, in accordance with 10 CFR

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50.82(a)(2), upon docketing of the certifications contained in the letters of June 26 and September 23,1997, the f acility operating license no longer authorizes Consumers to operate the reactor or emplace or retain fuelin the reactor vessel.

As described in the licensee's Post-Shutdown Decommissioning Activities Report (PSDAR), Revision 2, dated March 26,1998, Consumers has commenced plans to l immediately dismantle and decontaminate the BRP site, contingent upon continued access to one or more low-level radioactive waste (LLRW) disposal sites. The license.e also plans to construct and operate an independent spent fuel storage installation (ISFSI) for interim storage of the BRP spent fuel and has scheduled completion of site radiological restoration (excluding the ISFSI complex) in or about 2005.

BRP's existing or current TSs (CTSs) have been customized over the life of the plant to meet the specific needs of the facility and to maintain assurance that reactor operations would be conducted safely. The licensee also previously elected to maintain in its CTS LCOs, surveillance, and administrative controls for fire protection, quality assurance, radiological effluent control, and radiological effluent monitoring :nstead of removing these requirements from the TSs, as previous NRC guidance has suggested and would have Mowed with Commission review and approval. Therefore, the scope and format of the BRP TSs are site specific and not based on standardized format and content, such as that provided in NUREG-1433, " Standard Technical Specifications, General Electric Plants, BWR/4," which contains the latest NRC guidance on TSs for a BWR facility.

In the development of the proposed DTS, Consumers utilized other previously-approved defueled TSs in an effort to incorporate some degree of standardization in their site-specific TS format and content. These other defueled TSs included those used at the Portland General Electric Company Trojan Nuclear Power Plant, the Yankee Atomic Electric Company Yankee Rowe facility, and the Maine Yankee Atomic Power Station. Although these facilities are pressurized-water reactors, TS requirements involving the storage and control of spent fuel in a wet storage facility, radiological effluent control, quality assurance, radiological environmental monitoring, facility decommissioning activities and staffing, etc. are generally the same for facilities in the permanently shutdown and defueled condition. However, site-specific TS requirements may still be necessary to achieve adequate assurance of safety. The Consumers staff stated that they used the NUREG-1433 standard TS (STS) as another source of information and operating experience to obtain a better degree of standardization in its DTS.

l In general, the requirements and information in BRP's CTSs were either retained in the DTS, deleted, or relocated to licensee-controlled documents. New specifications were also added to the proposed DTS by the licensee to provide additional assurance that decommissioning activities would not result in conditions adverse to safety. These additional conditions included, in part, LCOs for spent fuel storage and programs for cold

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l l ~ weather' protection and SFP chemistry control. Consequently, the licensee has stated that l the cumulative effect of the requirements in the Facility Operating License No. DPR-6, i quality assurance plan, Updated Final Hazards Summary Report (UFHSR), other licensee l l programs, and NRC regulations continue to provide reasonable assurance that the decommissioning of BRP will not be inimical to public health and safety or the l environment.

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2.1 BACKGROUND

l Section 182a of the Atomic Energy Act (the Act) requires that applicants for nuclear l h

power plant operating licenses will state: l l [Sluch technical specifications, including information of the amount, kind,

[ and source of special nuclear material required, the place of the use, the

specific characteristics of the facility, and such other information as the j '. Commission may, by rule or regulation, deem necessary in order to enable it -

l to find that the utdization... of special nuclear material will be in accord with the common defense and security and will provide adequate protection to L the health and safety of the public. Such technical specifications shall be l

part of any license issued. .

1 In 10 CFR 50.36, the Commission established its regulatory requirements related to the content of TS. In doing so, the Commission placed emphasis on those matters related to i the prevention of accidents and mitigation of accident consequences. In particular, the i Commission noted that applicants were expected to incorporate into their TS "those items I that are directly related to maintaining the integrity of the physical barriers designed to contain radioactivity" (Statements of Consideration, " Technical Specifications for Facility Licenses; Safety Analysis Reports,". 33 FR 18610, December 17,1968). ' Pursuant to 10 CFR 50.36, TS are required to include items in the following five specific categories:

(1) safety limits, limiting safety system settings, and limiting control settings; (2) LCOs; (3) surveillance requirements (SR); (4) design features; and (5) administrative controls.

However, the rule doe.s not specify the particular requirements to be included in the TSs.

'10 CFR'50.36_ establishes four criteria to define the scope of equipment and parameters i to be included in the STS. Criterion 1 of 10 CFR 50.36(c)(2)(ii)(A) states that TS LCOs L must be established for " installed instrumentation that is used to detect, and indicate in the cor. trol room, a significant abriormal degradation of the reactor coolant pressure

boundary." Since all fuel has been removed from the BRP reactor vessel and a reactor l coolant pressure boundary (RCPB) is no longer applicable to a facility that is permanently shut down and defueled, this criterion is not applicable.

Criterion 2 of 10 CFR 50.36(c)(2)(ii)(B) states that TS LCOs must be established for a

! " process variable, design feature, or operating restriction that is an initial condition of a i

design basis accident or transient analysis that either assumes the failure of or presents a

[ challenge to the integrity of a fission product barrier." The purpose of this criterion is to i

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capture those process variables that have initial values assumed in the DBA and transient analysis and that are monitored and controlled during power operation. While this criterion was developed for operating reactors, there are some DBAs (such as fuel handling accidents) which continue to apply to a facility that has submitted the 10 CFR 50.82(a)(2) certifications, such as BRP, However, the full scope of DBAs applicable to such a plant is reduced from those postulated for an operating facility. For i

example, DBAs caused by an increase or decrease in reactor coolant inventory or heat I

removal by the secondary system, reactivity and power distribution anomalies, and core refueling accidents are no longer applicable. Consumers has determined that there are no operational transients that continue to apply to the BRP facility. Further, as evaluated later in this Safety Evaluation, the three reactor fission product barriers (the spent fuel clad, RCPB, and primary containment) are no longer required to assure public health and safety during normal or abnormal radiological conditions at BRP, Therefore, this criterion is no longer applicable.

Criterion 3 of 10 CFR 50.36(c)(2)(ii)(C) states that TS LCOs must be established for SSCs that are part of the " primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of the fission product barrier." The intent of this criterion is to capture into TSs only those SSCs that are part of the primary success path of a safety sequence analysis. Also captured by this criterion are those support and actuation systems that are necessary for items in the primary success path to successfully function.

The primary success path of a safety sequence analysis consists of the combination and sequences of equipment needed to operate (including consideration of the single failure criterion) so that plant response to DBAs and transients limits the consequences of these

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events to within the appropriate acceptance criterion. While Consumers stated that there are no operational transients that continue to apply to BRP, there are some DBAs that continue to apply to a plant only authorized to handle, store, and possess nuclear fuel; however, the scope of these DBAs is markedly reduced from those postulated for an operating plant. As stated in the prior paragraph, the failure of the fission product barriers does not represent a public health and safety concern. Therefore, this criterion is no longer applicable.

- Criterion 4 of 10 CFR 50.36(c)(2)(ii)(D) states that TS LCOs must be established for SSCs "which operating experience or probabilistic risk assessment has shown to be significant to public health and safety." The purpose of this criterion is to provide assurance that risk insights and operating experience are factored into the establishment of TS LCOs. None of the accident sequences that previously dominated risk at BRP due to operation of its reactor are now applicable, because the BRP reactor is permanently shut down and defueled. As discussed previously, the licensee used operating experience in the development of its DTSs.

The staff utilized the operating-reactor TS information presented above and the licensee's site-specific CTS in its evaluation of the BRP DTS. This is consistent with 10 CFR 50.36(c)(6) which states that for " nuclear power reactor facilities that have submitted the certifications required by 650.82(a)(1)... (tlechnical specifications involving

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' safety limits, limiting safety system settings, and limiting control system settings; limiting conditions for operation; surveillance requirements, design features; and administrative controls will be developed on a case-by-case basis." This provides reasonable assurance that the BRP DTS will be reserved for those matters as to whlch the imposition of rigid conditions or limitations on facility activities is necessary to obviate the possibility of an 1 abnormal situation or event giving rise to an immediate threat to the public health and i safety.

3.0 EVALUATION

. During reactor operation, the BRP nuclear steam supply system (NSSS) was a direct-cycle i BWR. Heat generated in the reactor vessel heated the incoming subcooled water supplied from two constant-flow recirculating water pumps located near the bottom of and external to the reactor vessel. As the water coolant passed through the core, it was heated to a two-phase mixture. Six 14-inch risers then carried the steam-water mixture

' from the reactor vessel to the steam drum, located above the reactor, where the steam was separated from the entrained water and dried. The separated water was then combined with feedwater pumped from the main condenser. This combined subcooled  ;

mixture flowed from the steam drum to two recirculating pumps that returned the water i to the reactor vessel. The dried steam exited the steam drum, drove the main turbine and electric generating equipment, and condensed in the main condenser. The resulting j s~

condensate was retumed to the steam drum as feedwater through a series of heaters and i

pumps.

The reactor coolant system (which formed the RCPB) consisted of, in part, the reactor vessel, recirculation system, and steam drying equipment, and is currently located within

.large, spherical, carbon steel, containment structure. During reactor operation, these

, SSCs and others assured that the release of radioactivity from " normal operation and 7 postulated accidents will be acceptably low" and less than the dose criteria established in 10 CFR Part 100, " Reactor Siting Criteria." These dose criteria are 25 rem whole body and 300 rem thyroid from iodines.

The most severe postulated accidents for operational nuclear power plants involve damage to the reactor core, failure of one or more fission product barriers, and the release of large quantities of fission products to the NSSS and/or the surrounding environment. These accidents would generally result from the failure or malfunction of SSCs necessary for safe reactor operation During power operation, the reactor operates at a saturation pressure of approximately 1,350 psia (pounds per square inch absolute), thereby providing a motive force to propel post-accident radioactive material into the spherical containment, I auxiliary buildings, or the environment following the failure of one or more safety-related SSCs. The BRP exclusion area boundary and low population zone distances were established to assure that facility operation and postulated accidents would not result in

, radiological conditione above the dose criteria in 10 CFR Part 100. The BRP UFHSR,

Revision 6 (which was the last applicable revision describing the operational status of the i

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..BRP facility), Chapter 15, Sections 15.1 through 15.9, described the following DBAs '

i> associated with reactor operation:

j :15.1 increase in Heat Removal by the Secondary System 2 15.2' Decrease in Heat Removal by the Secondary System

15.3- . Decrease in Reactor Coolant System Flow 15.4 Reactivity and Power Distribution Anomalies

' - l 15.5 increase in Reactor Coolant inventory l

'15.6 Decrease in Reactor Coolant Inventory }

15.7 Radioactive Release From a Subsystem or Component i 15.8 - Anticipated Transients Without Scram .

15.9 Single Loop Operation With the permanent cessation of power operation and the permanent removal of fuel from the reactor vessel, the operating reactor accidents described above are no longer possible nor applicable to the BRP facility. Therefore, the SSCs required to be operable during l reactor operation (including other modes of reactor operation such as hot standby and - '

~ cold shutdown) to mitigate or preclude UFHSR Chapter 15 accidents are no longer necessary. These SSCs include but are not limited to the reactor vessel, primary

containment, reactor coolant system (RCS), high and low pressure coolant injection systems, rod control, automatic isolation systems, electrical power distribution, automatic depressurization, safe-shutdown fire protection, and the majority of associated support systems. Nonetheless, the in-vessel fuel handling accidents described in UFHSR '

Section 15.7, " Radioactive Release from a Subsystem or Component," Revision 6, provides bounding-type information for fuel handling accidents that could occur in the SFP.

UFHSR, Section 15.7, Revision 6, described the licensee's evaluation of dropping the fuel transfer cask onto the reactor core, the dropping of a single fuel assembly onto the reactor core, and the loss of fuel transfer cask cooling. Consumers determined that the transfer cask drop onto the reactor core bounded the other two accidents. The cask drop onto the core would damage approximately 22% of the core resulting in a release to j

- containment atmosphere of 2.2% of the total noble gas content in the core. Assuming 1 representative times for alarms, indication, and automatic containment isolation, a site boundary gamma dose of 3.3 tads (assuming stack release of all noble gases released to containment with no isolation) and a maximum thyroid dose of approximately 2.5 rads would result. These doses are well.below 10 CFR Part 100 siting criteria of 25 rem whole J body and 300 rem thyroid. For comparison, the radiological consequences resulting from a fuel assembly drop accident would be approximately 1/20 of the cask <1 rop accident (or 1.2% of the core gap activity) and the loss of transfer cask cooling would be even smaller because it involves the damaging of only one fuel assembly.

Consumers also evaluated radiological event scenarios involving or associated with reactor j fuel storage or transport, as described in UFHSR Chapter 9, Revision 6. These evaluations l are listed below and remain applicable to the permanently shutdown and defueled BRP

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1 facilityihowever, because of radioactive decay of short-lived isotopes in the spent fuel, the offsite radiological consequence have decreased markedly since final reactor shut down.

9.1.2.1.3 _ Spent Fuel Handling Analysis 9.1.2.1.4 . Spent Fuel Pool Piping Systems and Failure Analysis 9.1.3.2 Spent Fuel Pool Cooling Failure Analysis -

9.1.3.4 Spent Fuel Pool Makeup Water (loss of makeup water) 9.1.3.4.1 Spent Fuel Pool Thermal Hydraulic Analysis 9.1.4.2.3 Fuel Transfer Cask Drop Analysis ,

9.1.4.7 Fuel Handling or Loading Analysis  !

9.1.4.7.2_ Fuel Bundle Drop Analysis 9.1.5.9 Protective Measure for Heavy Load Handling 9.1.B.1 Heavy Object Movement Analysis 9.1.7 Cask Movement / Drop Analysis 9.1.7.1 Spent Fuel Shipping Cask.

As described in UFHSR, Revision 7, dated February 12,1998, Consumers provided its reevaluation of the SRP accident analysis taking into account the permanently shutdown and_defueled condition of the BRP facility. Consumers stated that fuel handling accidents bound all'other categories of accidents with respect to the potential for offsite doses. The licensee also evaluated non-fuel events which could occur as a result of decommissioning, compared these events against the NRC's Final Generic Environmental

, Impact Statement on Decommissioning Nuclear Facilities" (NUREG-0586), and concluded that its planned decommissioning activities are bounded by the generic analysis. Further, in the assessment of radiological consequences, Consumers utilized the U.S.

Environmental Protection Agency's (EPAs) Protective Action Guides (PAGs). These guidelines established at 1 rem total effective dose equivalent (TEDE) whole body,5 rem comm;tted dose equivalent (CDE) thyroid, and 50 rem skin dose equivalent (SDE) are significant fractions below the 10 CFR Part 100 siting criteria.

Consumers has determined that the worst-case DBA applicable to the permanently shutdown and defueled BRP facility is the fuel transfer cask drop accident onto spent fuel stored in the SFP. Consumers hypothesized that the fuel transfer cask would damage and result in a gap release from a hypothetical 500 fuel assemblies, instead of the actual maximum CTS limit of 441 assemblies in the SFP. Although the damaging of 441 assembha is inconceivable for any drop pathway or configuration, the licensee used 500 assemblies to conservatively bound the radiological consequences of this DBA. In

! addition, the Consumers dose analysis utilized the radioactive source term associated with

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l a recen'jy discharged core (7 days old) following full power operations for one operating l~ cycle, provided no credit for containment ventilation isolation, established a minimum SFP I' ' water level of approximately 22 feet at the onset of the accident, and utilized the guidance in Regulatory Guide (RG) 1.25, EPA-400, and EPA-402. As shown in UFHSR

~ Figure 15.10.2-1, Damage to 500 Bundles," 68 days following plant shut down

- (November 5,1997) this hypothetical, worst-case accident results in offsite dose L consequences that are less than EPA PAGs.

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Consumers utilized a number of other conservatisms with its analysis of fuel handling accidents. The CTSs (reflecting the operation of the BRP facility) do not require and have not required containment isolation or closure during fuel handling in the SFP. However,  !

the licensee proposes a new term in its proposed DTS called " containment closure" and associated LCOs to provide defense-in-depth in controlling the spread of radioactive l contamination. Further, fuel handling personnel are trained and qualified to essentially the same criteria and procedures that were in existence prior to September 20,1997, the date that the last fuel assembly was removed from the vessel. Lastly, because RCS pressure and temperature no longer exists, there is no system-associated motive force to

} propel radioactivity from SSCs to the environment. Similarly, the spent fuel SSCs operate l under low pressure and tempereture and SFP SSCs are located and designed to preclude the release of radioactive contamination to the environment. Therefore, the migration of any radioactive contamination to the environment would occur primarily due to the evaporation of radioactive liquid or spread of dry contamination. These types of migration pathways (airborne and liquid) are no different now (during decommissioning) than they were during refueling or fuel handling during reactor operation. Finally, the possibility of a l I

fuel handling accident has been and continues to be remote due to the engineered features associated with fuel handling SSCs and the administrative controls and physical limitations imposed on fuel handling operations.

The licensee evaluated criticality of spent fuelin Chapter 15.10.2.2 of its UFHSR, Revision 7. Ccnsumers describes that its nuclear analyses were performed for anticipated normal and abnormal configurations in both the new and old fuel storage racks. In the worst-case situation, Consumers determined, assuming the most reactive temperature, calculational uncertainties, and accidents, "k" infinity would be less than 0.950 in the newer fuel storage racks and "k" effective in the older racks is approximately 0.08.

Further, the licensee evaluated cases that involved the inadvertent positioning (e.g., a I horizontal assembly position above the fuel racks and assembly storage in the water gap l between a rack and a SFP wall) of a fuel assembly in the SFP. Consumers determined that these situations are bounded by the cask drop case described above.

Consumers also considered the consequences resulting from the loss of all forced cooling l to the SFP. The licensee determined that 93 days following shut down (December 5, 1997), plant employees would have over 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to initiate make-up water to the SFP l at 20.8 gpm to maintain SFP temperature below the proposed DTS SFP temperature limit of 150 *F, assuming an initial SFP temperature of 80 *F. The heat generation rate that results in this temperature increase corresponds to 7.1ES Btu / hour (British thermal units per hour). For comparisons purpose, at the 300th day following shut down (June 1998),

heat generation was approximately 3.62E5 Btu / hour, which was a 50% reduction from the evaluated rate of 7.1ES Btu / hour. In approximately 500 more days (November 1999),

( the licensee calculated that the decay heat rate will approach an asymptotic value of

! approximately 1.2E5 Btu / hour (Figure 9-2, Spent Fuel necay Heat Curve," UFHSR, Revision 7). In its analysis, Consumers' letter to the Commission dated November 12, 1997, the licensee provided no credit for the thermal mass of the concrete support structure for the SFP or the temperature drops across the SFP liner and liner air gap.

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9 Conservatism was also factored into the proposed DTS SFP temperature limit of 150 "F, in that concrete failure does not occur immediately at 150 F but after a prolongeJ period of temperature above 150 'F. Therefore, with the significant reduction in the heat generation capacity of the spent fuel, a higher proposed DTS SFP fill rate of 28 gpm, and conservatism in the heat transfer model and tempeuture limit, ample margin exists before a high temperature SFP condition would result in conditions adverse to safety.

Consumers provided analysis in Revision 7 to its UFHSR showing that failure of SFP systems and piping would not result in conditions adverse to safety. Engineered features associated with the SFP and its supporting SSCs preclude the complete drainage of the SFP. The SFP concrete structure is lined with a 3/16 inch stainless steelliner and a SFP leakage detection system was previously installed to detect SFP leakage past the liner.

The licensee states that the SFP has been essentially leaktight with no measurable loss of water detected by the leak-detection system. Further, there is no SFP drain and a concrete weir prevents any piping failure from reducing SFP water level to below 20 feet above the top of the spent fuel assemblies. The licensee also previously installed an anti-siphon device in the SFP cooling inlet piping to the SFP to preclude SFP draining if this inlet piping breaks. In the SFP cooling system suction piping, which consists of the SFP surge tank, fuel pool filter tank, and other pipes, an anti-siphon device was installed to preclude SFP drainage should this suction piping break. The SFP make-up water piping discharges above the highest capable water level and cannot create a siphon.

In summary, the accident scenarios described in Chapter 15 of the UFHSR (Revision 6) are no longer applicable to the permanently shutdown and defueled condition of the BRP facility. The remaining postulated accidents, events or scenarios were evaluated by the licensee, described in the UFHSR, Revision 7, and used in the development of the proposed DTSs; these accidents represent a substantial reduction in radiological risk to public health and safety when compared to that of an operating reactor.

4.0 EVALUATION OF PROPOSED CHANGES TO LICENSE NO. DPR-6 AND ITS TS The proposed amendment: (1) removes license conditions and requirements that are no longer applicable to the BRP facility because the plant is permanently shut down and defueled, (2) relocates DPR-6 license conditions to Appendix A of the license to improve the implementation of requirements, (3) relocates selected Appendix A requirements to licensee controlled-documents in accordance with the Coramission Policy Statements and applicable NRC guidance, (4) retains license conditions and requirements that remain applicable, (5) adds new Appendix A requirements to enhance the assurance of maintaining public health anu safety, and (6) revises and edits license conditions and requirements to enhance clarity and better parallel the format and content of STS and TS that have been approved at other permanently shutdown and defueled power reactors.

The following is a discussion of the proposed amendment to Facility Operating License DPR-6 (Section 4.1) and Appendix A, Technical Specifications (Section 4.2). For consistency, the format of the DTS paragraphs discussed in this Safety Evaluation are in

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' the form'at, for ' example, "DTS 3/4.1.1.a," where "DTS 3.1.1.a" refers to the LCO portion of the TS and "4.1.1.a" refers to the SR for the particular LCO. Additionally, Section 4.3 of this Safety Evaluation summarizes editorial changes made by.the staff to enhance the clarity of the license. These changes were communicated to the licensee on September 10 and 11, and November 19,1998, and Consumers agreed to these changes by its letter dated November 25,1998.

4.1 Evaluation of Proposed Chanaes to License No. DPR-6 in paragraph 2.A. of the DPR-6 License, Consumers proposes to: (1) add the phrase

" decommissioning of" prior to the phrase "the Big Rock Point Plant;" (2) delne the phrase "a boiling water reactor and associated equipment;" and, (3) add the word

" updated" following the word " supplemented" and replace the comma after the word

" Report" with a semi-colon." By its letter dated December 21,1998, Consumers withdrew its proposal to add the phrase " decommissioning of" to the first sentence of l paragraph 2.A, because this change would have inadequately described the license issued  ;

to Consumers for the BRP facility. The staff also notes that the other changes described above do not remove necessary information or conditions from the license and reflect the ,

permanently shutdown and defueled condition of the BRP facility. The staff finds these changes acceptable.

In paragraph 2.B.(1), Consumers proposes to delete the license condition that Consumers may "use, and operate the facility. This change reflects the permanently shutdown and defueled condition or the BRP facility and is consistent with 10 CFR 50.82(a)(2). The staff finds this change acceptable.

- In paragraph 2.B.(2) Consumers proposes to: (1) delete the condition that Consumers may " receive" and "use" special nuclear material; (2) replace "as fuel" with "in fuel rods" to clarify the location of the uranium-235; and, (3) delete the phrase " ell in conjunction with operation of the facility, subject to the following conditions." These changes reflect the permanently shutdown and defueled condition of the BRP facility, are consistent with 10 CFR 50.82(a)(2), and do not remove any necessary information or conditions from the license. The staff finds these changes acceptable.

Consumers proposes to delete paragraphs 2.B.(2)(a), regarding, in part, reactor plant operation with an inadequate SFP make-up water line; 2.B.(2)(d), regarding, in part, the storage of spent fuel with a decay time of at least one year in the outer three rows of fuel l racks adjacent to the fuel pool south wall: 2.B.(2)(e), regarding, in part, the conduct of a human factors analysis of the meter on the noble gas stack monitor; 2.B.(2)(f), regarding the calibration of the high-range containment radiation monitors within manufacture's specifications; and 2.B.(2)(g), regarding advising " State and local planning authorities of l the view of the Atomic Safety and Licensing Board that further consideration should be given to whether there are practical means of expediting an evacuation that might be required during a rock concert or other major event at the Castle Farms site."

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Subparagraph 2.B.(2)(a) is no longer applicable in the permanently shutdown and defueled condition. Subparagraph 2.B.(2)(d) is no longer applicable because the nuclear fuel has been permanently removed fmm the reactor vessel for more than one year. As described in its letter dated December 21,1998, Consumers initially proposed that license condition 2.B.(2)(a) be relocated to the DTS: however, the licensee then withdrew this request, because all spent fuel at the BRP facility has aged more than 400 days. Nonetheless, the licensee proposes DTS 3/4.2.2.b to maintain the 2.B.(2)(a) condition that "frladiation levels at the south wall of the Spent Fuel Pool, elevaCon 600'6", shall be maintained less than 50 mrem /hr above background levels during fuel handling operations," with associated Actions and SRs. Subparagraph 2.B.(2)(e) is no longer applicable because this human f actors review was conducted during reactor operation. Subparagraph 2.B.(2)(f) is no longer applicable because there are no longer any normal or off-normal radiological conditions that could result in radiation conditions requiring the use of high-range containment radiation monitors. Subparagraph 2.B.(2)(g) is no longer applicable because the State and local planning authorities were advised of the views of the Atomic Safety Licensing Board during reactor operation. Further evaluation of these subparagraphs, in part, is provided in Section 4.2 of this Safety Evaluation. The staff finds these changes acceptable.

The licensee proposes to relocate the requirements of paragraphs 2.B.(2)(b), regarding the storage of materials in the area between rack B and the east wall of the spent fuel pool, and 2.B.(2)(c), regarding the use of the gantry crane over the spent feel pool for haR e over 24 ton 4, to its proposed DTSs 3/4.1.3.b and 3/4.3.1.a, respectively. The stah nds the relocation of these requirements to the DTS acceptable, because these hense conditions are in a format consistent with an LCO, which is defined in 10 Cr . 50.36(c)(2) as "the lowest functional capability or performance levels of equipment required for safe operation of the facility." Thus, the pre,sosed relocation of these license conditions improves the implementation of these requirements and is consistent with 10 CFR 50.36(c)(6). Additional evaluation of this change is provided in Section 4.2 of this Safety Evaluation, in paragraph 2.B.(4), Consumers proposes to delete the condition that Consumers may

" receive" and "use" up to 500 kilograms of depleted uranium dioxide contained in the facility's fuel assemblies. This change redlects the permanently shutdown and defueled condition of the BRP facility and ia consistent with 10 CFR 50.82(a)(2). The staff finds this change acceptable.

In paragraph 2.C.(1), Consumers proposes to delete the title " Maximum Power Level," and condition *lt]he licensee is authorized to operate the f acility at steady state reactor core power levels not in excess of 240 megawatts (thermal)," because the facility has permanently ceased reactor power operation. The staff notes that these proposed changes ref!act the permanently shutdown and defueled conditions of the facility and finds these changes acceptable. Consumers also proposes to replace the deleted 2.C.(1) title and condition with the new title " Maximum Power Level," and the new condition that

"(t]he reactor is not licensed for power operation. Fuel shall not be placed in the reactor l

vessel." The staff notes that the proposed replacement title and condition reflect the

. permanently shutdown and defueled condition of the facility and that this proposalis consistent with 10 CFR 50.82(a)(2). The staff finds these changes acceptable.

l

.in paragraph 2.C.(2), the licensee proposes to replace the word " operate" with the word

" maintain." This change reflects the permanently shutdown and defueled condition of the l BRP facility and is consistent with 10 CFR 50.82(a)(2). The staff finds this change

! acceptable.

The licensee proposer to delete paragraph 2.C.(3) regarding exemption from emergency l core cooling system failure criteria; 2.C.(4), regarding fire protection; 2.C.(6) regarding the l recirculation pump trip, anticipated transient without scram, and an associated l probabilistic risk assessment; and,2.C.(7) regarding the " Plan for the Big Rock Point l- Integrated Assessment." Regarding paragraph 2.C.(4), the specific conditions have been j l

completed or are no longer required due to the permanently shutdown and defueled I condition of the BRP facility. Further, fire protection requirements may be relocated to

. licensee-controlled documents as described in Section 4.2 of this Safety Evaluation.

DPR-6 paragraphs 2.C.(3), '2.C.(6), and 2.C.(7) are specifically applicable to reactor power operation of the BRP facility. Therefore, these requirements are no longer applicable because the BRP facility is permanently shot down and defueled. The staff finds these changes acceptabie.

l .The licensee proposes to renumber the currently approved license condition 2.C.(5),

"Phycical Security," as license condition paragraph 2.C.(3), which was deleted as discussed in the previous paragraph. Further, Consumers proposes to delete the word "previously" as used in the first sentence of the physical security license condition. The

!' staff notes that the renumbering of licensee condition 2.C.(5) as license condition 2.C.(3) and the deletion of the word "previously" are editorial changes that do not reduce or change any conditions of the DPR-license. The staff finds these changes acceptable.

4.2 Evaluat:on of Proposed Chanoes to Aooendix A of License No. DPR-6 CTA SECTION 1, INTRODUCTION CTSs 1.0,1.1, and 1.1.1 through 1.1.3 describes, in part, the purpose of CTSs, provides a summary of the CTS Table of Contents, and discusses that the dimensions and numerical values used in the CTSs are subject to normal manufacturing tolerances. The information provided in these CTS paragraphs is for information. The licensee proposes to delete these sections.

CTS 1.1.4 describes information regarding the conduct of surveillance and also states that each CTS surveillance requirement shall be conducted within the specified surveillance l

interval or within a maximum allowable extension not to exceed 25% of the specified 4

surveillance interval. The licensee proposes to move the 25% surveillance extension

, allowance to DTS 4.02.

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1 The licensee also proposes DTSs 3/4.0.1, 3/4.0.2, 3/4.0.3, and 3/4.0.4 as new requirements in the conduct of DTS surveillances. These DTS requirements are based on STS, defueled TSs currently in use at other permanently shutdown power plants, and are applicable to the BRP facility. These DTSs are introduced by DTS 3/4, " Limiting Conditions for Operation and Surveillance Requirements," and DTS 3/4.0, " Applicability."

CTS 1.2 contains definitions for terminology that is unique to the BRP facility and an introductory paragraph for informatior purposes. The introductory paragraph and defin'tions associated with reactor operations are proposed for deletion. These definitions include that for power operation (CTS 1.2.1), core alteration (CTS 1.2.2), refueling operation (CTS 1.2.3), major refueling (CTS 1.2.4), shutdown (CTS 1,2,5), cold shutdown (CTS 1,2,6), dose equivalent iodine (CTS 1.2.7), and source check (CTG 1.2.12). As defined in the CTS, these definitions are not applicable to the permanently shutdown and defueled condition of the BRP facility. Regarding CTS 1.2.7, dose equivalent iodine, the licensee stated in its letter dated July 21,1998, that more than 10 half lives of iodine have occurred since reactor shut down on August 20,1997; therefore, these radioactive isotooes no longer exist. The licensee also proposes to delete the CTS 1.2.13, " Member of the Public," becouse this definition is provided in 10 CFR Part 20, and to renumber CTS 1.2 as DTS 1.0.

Consumers Energy proposes to change a number of definitions to improve their clarity or applicability to the permanently shutdown and defueled condition of the BRP facility.

These changes include definitions for channel calibration (CTS 1.2.9 as DTS 1.3); channel check (CTS 1.2.10 as DTS 1.4); channel function test (CTS 1.2.11 as DTS 1.5); and reportable event (CTS 1.2.14 as DTS 1.14). The licensee also proposes to remove the description related to bistable cha,nels in the definition of channel functional test. These changes are administrative and the description related to bistable channels is not necessary to be included in TSs, because the proposed DTS do not have SRs associated with bistable testing of instruments and a description of bistable channels does not meet the criteria of 10 CFR 50.36(c)(2)(ii).

The licensee proposes to relocate CTS 1.2.8, " Operable - Operability," as DTS 1.12 and proposes a change to this definition to better align it with th9 definition provided in NRC Manual Chapter 9900, " Technical Guidance," entitled " Operable / Operability: Ensuring the Functional Capability of a System or Component."

Consumers Energy proposes to add eleven new definitions: DTS 1.1, " Action;" DTS 1.2,

" Certified Fuel Handler;" DTS 1.6, " Containment Closure;" DTS 1.7, " Direct Path;"

DTS 1.8, " Fuel Handling;" DTS 1.9 "Immediately;" DTS 1.10, " Monitoring Station;"

DTS 1.11, "Offsite Dose Calculation Manual (ODCM);" DTS 1 13, " Process Control Program (PCP);" DTS 1.15, " Shift;" and, DTS 1.16, " Site Boundary." These changes clarify terms and conditions used in the DTS and are considered administrative, except as provided as follows. Regarding the definitions for containment closure and direct path, although Consumers determined that offsite dose consequences are less than EPA PAGs assuming no credit for containment or ventilation during JBAs, the licensee proposes (as

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previously described) administrative controls for the BRP spherical enclosure to provide defense-in-depth in the control of radiological contamination during fuel handling l (DTS 3/4.2.1.a) and heavy load operations (DTS 3/4.3.1.d). Thus, containment integrity, I

leak tightness, and/or the spherical enclosure itself are not required to assure public health and safety during normal or abnormal radiological conditions. The definition for " direct path" provides additional clarifying information for " containment closure" requirements.

~

Consumers proposes the definition " monitoring station" to describe the location from l which station command and control will be conducted. This definition provides a functional description of the facility control station and clearly differentiates this station from the " control room," a term historically associated with reactor operations. Finally, regarding the definitions for ODCM and PCP, the proposed definitions represent a condensed version of the information provided in CTS Sections 13.1 and 13.2.

l The staff finds the above changes to Section 1 acceptable.

CTS SECTION 2,3. LIE l

CTS 2.0 describes the location of the BRP facility, the boundaries of the licensee's site property, and the principal activities that will be performed on the site. As indicated l'

above, Consumers proposes DTS 1.16, " Site Boundary," as "that line beyond which the land is not owned, leased, or otherwise controlled by the licensee." Further, the licensee proposes to relocate and administratively revise CTS 2.1, " Location," and DTS 2.2,

" Boundaries," as DTS 5.1.1, " Location and Boundaries," whila maintaining all relevant location and boundary information. Also, CTS Figure 2.1 was relocated in its entirety as DTS Figure 5.1-1 and the licensee proposes deletion of CTS 2.3, " Principal Activities,"

, because this CTS provides a definitbn that is not applicable to the permanently shutdown and defueled condition of the BRP facility. The staff finds these changes acceptable.

CTS SECTION 3 REACTOR CONTAINMENT l

CTS Sections 3.0 through 3.7 describes the engineered features and requirements associated with the containment sphere, post-accident containment spray system, and containment leakage rate. These requirements and the engineered features provide assurance that reactor power operations and the radioiogical consequences resulting from postulated accidents and natural phenomena (UFHSR Chapter 15, Revision 6) do not result in conditions adverse to public health and safety. Specifically, this section describes features of the reactor containment system (such as materials, dimensions, pressure ratings, construction, and testing requirements) that, if changed during reactor op'erations, could adversely impact safety. The licensee proposes to delete CTS Section 3 in its entirety.

i-i The specific design features associated with the reactor containment system (CTSs 3.0

'through 3.3) including, but not limited to, design pressure and temperature ratings, wind l and snow loading, lateral seismic acceleration, permissible air leakege at 41.7 psia, 1

l containment sphere dimensions, construction information, and design features associated with containment penetrations are maintained in licensee-controlled documents. Further, this CTS information was to support reactor power operations and to prevent the spread of radioactivity and contamination following design-basis reactor accidents involving high pressures and temperatures in the RCS.

In particular, CTSs 3.4.1, 3.4.2, 3.4.3, 3.6, and 3.7 describes methods of containment closure, integrity, operating requirements for containment penetrations, and containment sphere leakage testing requirements. These requirements were set forth to assure that containment and its penetrations are appropriately controlled, configured, and tested to mitigate the release of radioactivity to the environment following a reactor power accident; in addition, double closures, gasketed sealing devices, valve isolations, automatic closure devices, and vacuum reliefs were engineered features that contributed to this assurance. Testing requirements (such as Type A, B, and C leakage rate testing pursuant to Appendix J of 10 CFR Part 50) for containment integrity and its penetrations has been required because operating-type of reactor accidents results in elevated temperatures and pressures within containment and acts as a motive force for the release of radioactivity to the environment. Within these requirements, there are also visual examination, post-maintenance, and automatic controls and instrumentation requirements associated with maintaining the pressure retaining capability of the spherical containment during DBA conditions.

The licensee also proposes to delete CTS 3.5, " Post-Accident Spray System," in its entirety. This CTS includes design features and operating requirements necessary to assure that the spherical enclosure will not be over pressurized during loss of coolant accidents.

Because the reactor is permanently shut down and defueled, the staff finds the above changes to Section 3 acceptable, i

CTS SECTION 4, BEACTOR AND POWER SYSTEMS EQUIPMENT CTS 4.1, " Reactor System Equipment," describes design features and requirements associated with the reactor vessel, primary coolant recirculation system, and primary system shielding. This section provides descriptions, settings, dimensions materials, and operating requirements for safety relief valves, reactor shutdown cooling, reactor emergency cooling, core spray, backup core spray, core spray recirculation, and primary i system leakage requirements. Additionally, prc~,ure-temperature limit curves are provided for reactor operation nil-ductility temperature determinations and to preclude failure of the reactor vessel during power operations. These design features would be maintained in licensee-controlled documents, such as the UFHSR. This CTS also requires i isotopic analysis of primary coolant for iodine-131, system leakage limits, and shielding l requirements. The licensee proposes to delete this section. The above mentioned reactor l system equipment, infortnation, and LCOs are for reactor power operation and are no I

longer necessary for a plant that is permanently shut down and defueled. Further, I

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iodine-131 has experienced more than 10 half lives and no longer represents a public health and safety concern. The staff finds this change acceptable.

CTS 4.2.1, " Electrical System," was deleted previously during a prior license amendment.

CTSs 4.2.2 through 4.2.4 and 4.2.10 describe design features and requirements associated with the main condenser, turbine bypass control system, condensate feedwater system, and turbine generator unit. These systems were necessary for reactor power operation to generate electricity, supply feedwater to the reactor vessel, and to provide over-pressure protection and pressure control during rt. actor operations. The licensee proposes to delete these sections. These NSSS systems are not required for a permanently shutdown and defueled reactor. The staff finds these changes acceptable.

The description and requirements in CTS 4.2.5, " Reactor Cooling Water System,"

prevides assurance that adequate cooling water is available for reactor shield cooling panels, reactor clean-up nonregenerative heat exchanger, reactor shutdown heat exchanger, miscellaneous sample coolers, reactor recirculation pump coolers, and the SFP cooling water heat exchanger. The licensee proposes to delete this section. As evaluated by the licensee, DTS operability of these systems is not required because the loss of cooling water is not inimical to public health and safety in the current permanently shutdown and defueled condition. Consumers demonstrated that spent fuel decay heat is insufficient to result in conditions that could adversely impact the SFP structure, SFP level, or storage of spent fuel. In addition, naturally-occurring heat transfer to environmental and structural surroundings (which the licensee has conservatively evaluated) and reasonable operator actions provide assurance that adverse conditions resulting from a loss of cooling will not occur. Additionally, SFP systems were designed for the thermal conditions associated with post-reactor operations, such as refueling.

Therefore, the operating-reactor heat loads described in CTS 4.2.5 are significantly higher than the heat loads currently associated with spent fuel storage at the permanently shutdown and defueled BRP f acility. Lastly, additional margin exists because the spent fuel decay heat continues to decrease as the spent fuel ages. The staff finds this change acceptable.

CTS 4.2.6 provides requirements for the fire protection system. The licensee proposes administrative changes to and relocation of the majority of this information to licensee-controlled documents. This CTS states that tha fire protection system shall provide water to core spray cooling, backup core Lpray cooling, containment sphere l post-accident spray, and backup service water to the spherical enclosure. This water supply requirement also increases the number of water sources available for use during l

reactor post-accident conditions. Core spray cooling, backup core spray cooling, l

containment sphere post-accident spray, and back-up service water to the containment i

sphere are necessary for accident mitigation during power reactor operation. Further, in Consumers letter dated July 21,1998, the licensee stated that prior to Revision 7 of the UFHSR, there was a one to-one correlation between the CTS and the UFHSR regarding fire protection requirements. Subsequently and after permanent shutdown of the facility

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i l 'on August 30,1997, the licensee updated tne UFHSR to delete fire protection l requirements and information specifically applicable to reactor power operation. s Consumers also stated that there were no changes made to the BRP fire protection plan L and that procedure controls have not been changed since final plant shut down. i

! Therefore, as provided in Generic Letter (GL) 88-12, " Removal of Fire Protection Requirements from Technical Specifications," the licensee has demonstrated that fire protection requirements have been adequately incorporated into licensee-controlled documents. Further, (1) changes have not been proposed by the licensee that would adversely impact the safe storage, maintenance and control of spent fuel and (2) proposed l L ' DTS 6.6.2.7 states that a fire protection program meeting the requirements of l 10 CFR 50.48(f) shall be established, implemented and maintained. This regulation also requires that a licensee may make changes to its fire protection program without NRC approval, as long as the changes do not reduce the effectiveness of fire protection for L facilities, systems, and equipment. The fire protection program is inspectable and

! enforceable.

Lastly, the licensee proposes to delete the design ratings of the electric and diesel fire l pumps from the TSs and maintain this information in UFHSR, Revision 7, Chapter l 9.5.1.2.1. The staff notes that the removal of this design information from the TS is j- consistent with GL 88-12 and is not required to be in the TSs as described in 10 CFR j 50.36(c)(2)(ii). Further, the diversity and capacity of the CTS 4.2.6 pumps (which are

! designed for reactor operation and post-accident conditions) are not required for the current condition of the SFP, because of the significantly reduced SFP heat load.

l Nonetheless, the licensee proposes DTS 3/4.1.2, in part, to ensure that acceptable make-up water sources are available to the SFP. The staff finds the relocation of fire

( ' protection requirements from CTS 4.2.6 acceptable.

CTSs 4.2.7,4.2.8, and 4.2.9 provides design and operational information for the primary

containment ventilation, reactor service water, and service and instrument air systems.

l These CTSs were required, in part, to assure safe reactor power operation by contributing to post-DBA mitigation. CTS 4.2.7 information is provided in the ventilation system description in Chapter 9.4.6 of Revision 7 to the UFHSR. This information includes volumetric flow rates, air and release pathways, and other design-related information.

I These design considerations provided assurance that radiological conditions within the spherical enclosure allowed personnel access and minimized the spread of contamination.

As described in UFHSR Chapter 9.4.2, Revision 7, Consumers will continue to maintain adequate ventilation to support the SFP system, which is located inside the spherical l enclosure. Further, the licensee proposes _DTS 1.6, a ventilation / physical configuration described as " containment closure," as "that condition of containment in which there are no direct paths from containment atmosphere to the outside atmosphere, except for the containment ventilation inlet and exhaust valves, which may be opened if at least one

! exhaust fan ir,in operation. Leaktightness is not required for containment closure." The

' licensee also provided additional detail as to the physical condition of containment closure i by stating that the establishment of this condition does not preclude the passage of

i. material or personnel through containment double-door hatches nor require redundancy.

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3 Further,' Consumers provided analyses in Chapter 15 of its UFHSR, Revision 7, demonstrating that the worst-case, fuel-related accident would not result in offsite dose

- consequerices exceeding EPA PAGs even assuming no credit for the containment structure,' closure, or ventilation. Therefore, the spherical enclosure and/or containment closure are not required to mitigate offsite radiological risk in the current condition of the BRP facility. Additionally, the licensee's proposed DTS for containment closure during fuel handling (DTS 3.2.1) and heavy load operations (DTS 3.3.1) are defense-in-depth strategies to control the spread of radioactive contamination; they are not necessary to provide adequate assurance of public health and safety during normal or abnormal radiological conditions.

Additionally,10 CFR Part 20 provides requirements to minimize occupational exposure and control the spread of radioactive contamination. The licenseo has also stated in

' Revision 2 of its Post-Shutdown Decornmissioning Activities Report that they will maintain the capability to control air flow from the reactor and turbine building and the liquid radioactive waste vault to the environment through monitored pathways. This ventilation pathway is further described in Chapter 6.2.12 of the UFHSR, which states that the containment ventilation pathway is provided by two full-capacity fans (each rated to 30,000 cubic feet per minute) which moves air from areas of lowest radioactive contamination probability toward areas of highest contamination probability and then out the plant stack. Further, the licensee is required by regulation and by proposed '

DTSs 6.6.2.4, "Offsite Dose Calculation Manual (ODCM)," 6.6.2.5, " Radiological Effluent L

Controls Program," and 6.6.2.6, " Radiological Environmental Monitoring Program," to monitor pathways associated with the release of radioactive material to the environment.

Regarding the design and operability information associated the reactor service water system (CTS 4.2.8) and the service and instrument air systems (CTS 4.2.9), these CTSs are predominately at.sociated with reactor power operation and are not applicable to the permanently shutdown and defueled condition of the BRP facility. Further, as previously described, that portion of the reactor service water system supplying the SFP cooling heat exchanger was based on the design heat load of the SFP during refueling operations. The licensee has demonstrated that the SFP heat load has significantly reduced since final reactor shut down and it continues to decrease. Additionally, the DTS proposes LCOs for l

SFP level (DTS 3/4.1.1.a) and high and low SFP temperature (DTS 3/4.1.1.b) to provide further assurance that appropriate operator actions will be taken to restore SFP level and temperature.

The staff finds the changes to CTSs 4.2.7, 4.2.8, and 4.2.9 acceptable.

CTS 4.2.11, FUEL STORAGE CTS 4.2.11 provides design and operational instructions for fuel storage, fuel handling, and the SFP make-up water system. The CTS introductory paragraph provides information on fuel handling. This information was incorporated into DTS 3/4.2.2, " Fuel Handling General Requirements," including fuel handling LCOs for water shielding i

4 0 i- l L

l (DTS 3/4.2.2.c) and manual guidance (DTS 3/4.2.2.d). The licensee proposes to delete information regarding the use of the lead-shielded transfer cask and associated spent fuel lifting equipment. The NRC staff notes that the CTS does not provide explicit LCO conditions for the use of this equipment and LCO conditions for spent fuellifting equipment are not required when compared to the criteria of 10 CFR 50.36(c)(2)(ii). The staff finds these changes acceptable.

1 CTS 4.2.11(a) provides information on new fuel storage. All fuel at BRP is spent fuel and  !

with the issuance of this amendment, new fuel is precluded from being stored or used at the BRP facility. Therefore, CTS 4.2.11 is not applicable in the current condition of the BRP facility. The staff finds this change acceptable.

CTS 4.2.11(b) provides information on spent fuel storage. The proposed DTS maintains LCOs for spent fuel storage in SFP sacks (DTS 3/4.1.3.a), spent fuel criticality limits (DTS 5.2.1), fuel movement in inspection stands for inspection (DTS 3/4.2.2.a and

{

' 5.2.1), maximum SFP capacity for spent fuel at 441 assemblies (DTS 5.2.4), and lifting of '

one assembly at a time (DTS 3/4.2.2.a). The licensee also proposes DTS 5.2, " Storage and Inspection of Spent Fuel," and DTS 5.2.1, " Criticality," as introductory paragraphs.  !

The staff finds these changes acceptable, because CTS requirements are maintained in the i DTS requiring that spent fuel be stored and lifted safely. ]

The licensee proposes to relocate DPR-6 requirement 2.B.(2) to the proposed DTS and make editorial changes. Specifically, Consumers proposes to: (1) relocate and i administratively edit DPR-6, 2.B.(2) phrase " Pursuant to the Act and 10 CFR Part 70,

'Special Nuclear Material,' to receive, possess, and use at any one time up to (a)..., (b)...,

(c)..., and,1(d)..." as DTS 5.2.4; (2) delete the words "as fuel" as used in DPR-6 sentence "2500 kilograms of contained uranium 235 as fuel;" (3) delete the word " neutron" as used in DPR-6 phrase "5 curies of plutonium encapsulated as a plutonium-beryllium neutron source;" and, (4) delete the phrase "allin connection with the operation of the facility, subject to the following conditions." Additionally, Consumers proposes to: (a) delete DPR-6 paragraph 2.B.(2)(a) because this license condition is applicable to reactor power operation and (b) relocate and editorially revise: (i) DPR-6 paragraph 2.B.(2)(b),

"The storage of materials in the area between rack B and the east wall of the spent fuel pool is prohibited," as DTS 3/4.1.3.b and (ii) DPR-6 paragraph 2.B.(2)(c), "The use of the gantry crane over the pool for loads of over 24 tons is prohibited," as DTS 3/4.3.1.a.

Changes (1), (2), (3), and (4) are considered administrative changes and do not reduce license requirements. Change (a) is proposed because it is no longer applicable because the plant is permanently shut down and defueled and change (b) relocates TS requirements without any reduction in requirements. The staff finds these changes acceptable. Additional evaluation of these changes is provided in Section 4.1 of this Safety Evaluation.

The licensee proposes to delete the operability requirements paragraph for the SFP make-up water system (CTS 4.2.11) because this requirement pertains to reactor plant r operation. However, Consumers proposes DTS 3/4.1.2 to ensure that there is an l

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adequate make-up water source to the SFP during the conduct of decommissioning.

DTS 3/4.1.2.a requires that a capability to provide make-up water to the SFP shall be l ' maintained either by (1) a diesel generator providing power to an onsite electric l motor-driven pump, (2) one offsite electrical power source to an onsite electric motor-driven pump, or (3) an onsite pump not requiring electric power. DTS 3/4.1.2.b  !

req'uires that these pumps supply water at a flow rate of at least 28 gpm at a temperature equal to or less than 100 *F and a capability to manually initiate at least 28 gpm flowrate

! - to the SFP shall be maintained.

l The staff notes that the licensee proposes DTS 3/4.1.2 based on its assessment of risk.

, Due to the historical leak tightness of the SFP, calculated evaporation rate of SFP water,

!' engineered features to preclude significant draining of the SFP, and the rate of SFP temperature increase on a loss of SFP cooling or make-up, the 24-hour make-up requirement and manualinitiation of make-up provides assurance that conditions adverse

to safety do not occur. Further, the redundancy and diversity of the power supplies for I 'the make-up water pumps provides defense-in-depth and additional assurance of safety; this redundancy and diversity is similar to the fire protection requirement of CTS 4.2.6.

The 28 gpm flowrate and.100 *F temperature limits are consistent with licensee analysis.

Consumers proposes the DTS 3/4.1.2 SRs to assure the operability of the SFP make-up water sources. These surveillances include daily verification of voltage potential of the i

. offsite power supply, monthly (once per 31 days) operational test and flowrate verification for the pumps and diesel generator, and a yearly (once per 12 months) flowrate test from the source to the SFP. These SRs provide assurance that periodic testing of SFP make-up water supplies will be conducted to ensure that they are capable of meeting their intended safety function.

The staff notes that the CTS do not have requirements for SFP make-up water with the

reactor shut onwn. Thus, the proposed requirements are new and provide adequate assurance that make-up water and electrical power is available to refill the SFP and to l provide cooling utilizing a feed-and-bleed operation, if necessary. The staff finds DTS l 3/4.1.2 and the relocation and deletion of CTS 4.2.11 requirements, as described above, acceptable.

The licensee proposes DTS 3/4.3.1.a and b to provide assurance that the handling of

[ heavy loads over or in the SFP is conducted safely. As evaluated in Section 4.1 of this Safety Evaluation, DTS 3/4.3.1.a originates from the relocation of license condition

.B.(2)(c) regarding the use of the reactor building crane. This license condition is further described in Chapter 9.1.2 of the UFHSR, Revision 7, in that the licensee has committed to obtaining NRC review and approval prior to any use of any fuel transfer cask weighing more than 24 tons. The licensee also proposes new TS requirement DTS 3/4.3.1.b to provide assurance that important administrative requirements of UFHSR, Revision 7, Chapter 9, Table 9-1, will be accomplished. This new requirement consists of (1) preventing the movement of the cask over spent fuel stored in the SFP, (2) limiting cask

handling operations to the southwest corner of the SFP, and (3) preventing the storage of fuelin the storage racks adjacent to the cask handling area in the southwest corner of the l

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, SFP during cask handling operations. As described in the Bases for DTS 3.3.1, a heavy load is defined as "500 pounds (the weight of a fuel assembly and the handling equipment)."

The staff notes that proposed change to place the UFHSR administrative requirements into the DTS provides reasonable assurance that the handling of heavy loads in close proximity l to spent fuel will be conducted safely. In addition, DTS 3/4.3.1.b mitigates the radiological consequences of inappropriate cask handing (for example, tipping the cask onto or bumping the cask into spent fuel) or a cask drop accident. Further, the movement of heavy loads, as described, was previously reviewed and evaluated by the NRC and the conduct of fuel handling is either bounded by current requirements and analysis or will be subject to NRC review and approval. The proposed action statement provides reasonable assurance that appropriate actions will be taken if the LCO is not met (such as placing the crane in safe condition, suspending further load handling activities with the reactor building gantry crane, and obtaining Site General Manager approval prior to recommencing load handling). The SRs provide assurance that, prior to the conduct of heavy load handing over the SFP, the plant staff will verify that the load does not exceed 24 tons, that the load is properly rigged, that the trip mechanism of the cask safety catch device is functionally tested, and that containment closure exists. As described in this Safety Evaluation, CTS 7.4(j) regarding the trip mechanism was relocated as DTS 3/4.3.1.c and equivalent requirements were maintained. Further, the establishment of containment closure during heavy load operations is a defense-in-depth strategy to minimize the spread of radioactive contamination should a heavy load accident or off-normal condition occur. The staff finds these changes acceptable.

CTS SECTION 5, REACTOR CORE AND CONTROLS CTSs 5.0 througn 5.2.6,~ with tables and figures, provides design information for core materials, control rod assemblies, control rod drives, liquid poison system, fuel enrichment, general core data, radioactive neutron sources, principal core operating limitations, control rod system, reactivity coefficients, and reactivity additions during core l alterations and power operations. This CTS information was necessary for reactor power operation and is no longer necessary for the permanently shutdown and defueled condition of the BRP facility. This information will be maintained in licensee-controlled documents, as necessary. The licensee proposes to owlete Section 5 in its entirety. The j licensee also proposes DTS 5.3, " Reactor," and DTS 5.3.1, " Status," as design features l associated with the BRP facility stating that "[t]he reactor is not licensed for operation.

l Fuel shall not be placed in the reactor vessel." The staff notes that these DTSs are for l reactor operation and are not necessary for the permanently shutdown and defueled condition of the BRP facility. The proposed change to DTS 5.3 and 5.3.1 is consistent with 10 CFR 50.82(a)(2). The staff finds these changes acceptable.

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I CTS SECTION 6, PLANT SAFETY AND MONITORING SYSTEMS CTSs 6.0 through 6.2.2 provide design information on plant safety and monitoring systems. These systems include sensing devices and associated circuits that automatically initiate a reactor scram or other required action. Response times, operability requirements, and trip points are also provided. Devices and circuits also include neutron monitoring and power level instrumentation, reactor safety system bypass, containment penetre non closure, emergency condenser control, and control rod permissives. The licensee proposes to delete these sections in their entirety, because these sections are associated with resctor power operation and reactor core refueling. Further, the CTS requirements for containment sphere isolation are associated with reactor operation and post-accident, operating-reactor conditions, such as low reactor water level, high enclosure pressure, and loss of auxiliary electric power supply (CB-E11 A & CB-RE11B).

Similarly, CTS 6.1.3 discussion regarding mode selector switch positions and conditions are also not applicable during a permanently shutdown and defueled condition. The staff finds these changes acceptable.

CTS 6.3 provides LCOs and operationalinformation for the refueling operation interlock system. CTS 1.2.3 defines a refueling operation as any operation with any of the reactor vessel closures open during which a core alteration or other operation which might increase core reactivity is in operation. CTS 1.2.2 defines a core alteration as any completed planned sequence of movements of core components resulting in either a net change in the configuration of the core or a net gain in core reactivity. The licensee proposes to delete CTSs 6.3,1.2.2 and 1.2.3, because they are not applicable to a permanently shutdown and defueled condition. The staff notes that with the BRP reactor permanently shut down and defueled, these CTSs are no longer applicable. The NRC staff finds these changes acceptable.

CTS 6.4 provides LCOs and design information on process radiation monitoring systems, the area radiation monitoring system, the reactor water level monitors in the reactor depressurization system, and the containment pressure and water level monitoring system. The air ejector offgas monitoring and the emergency condenser vent monitor systems are associated with reactor operation and are not required in the permanently shutdown and defueled condition. The stack gas monitoring and process liquid monitor systems are applicable to the current condition of the BRP facility; however, the LCOs have been revised by the licensee to reflect the current condition of the facility (see i further discussion below). The licensee also proposes to delete CTS 6.4.1(e) because

there is no necessity to measure radioiodines under accident conditions since more than 10 half lives of iodine isotopo decay have occurred since permanent shut down on August 30,1997. The staff finds these changes acceptable.

The licensee proposes to revise and relocate CTS 6.4.2, " Area Monitoring System," as DTS 3/4.1.1.d and DTS 3/4.2.1.a and b. Equivalent CTS 6.4.2 requirements were maintained in the proposed DTSs; however, Consumers proposes to remove reference to:

(1) the adjustability of the "high radiation alarm which shall alarm in the control room;"

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l e o (2) a fixed gamma monitor in the control room; (3) calibration and alarm setting information; and, (4) the containment atmospheric high-range gamma monitors.

The staff notes that these CTS requirements and information were for reactor power operations and associated operating-reactor DBAs and are not applicable during the permanently shutdown and defueled condition. In particular, item (1) was to ensure, in part, that control room operators could adjust the set point to track the severity of a reactor accident; item (2) was provided, in part, so that control room operators could j evaluate control room habitability during post-reactor accident recovery; item (3) was provided, in part, to ensure that the instruments are properly maintained and operable; and item (4) was provided to monitor the containment atmosphere following a reactor accident. Because the reactor is permanently shut down and defueled, items (1), (2), and (3) are not required. In addition, the deletion of item (4) is consistent with 10 CFR 50.36(c)(2)(ii) criteria, because there no longer exists a design-basis accident warranting a containment atmospheric high-range gamma monitor. Nonetheless, regarding gamma monitoring, the licensee proposes DTSs 3/4.1.1.d and 3/4.2.1.b requiring radiation monitors in the area of the SFP to monitor and alarm remotely and locally if abnormal radiation conditions occur.

Regarding the CTS 6.4.2(b) requirement that the containment ventilation valves be closed if the refueling deck. radiation monitors are inoperable during fuel handling, the licensee proposes (1) DTS 3/4.2.1.a that requires containment closure and capability to close the containment ventilation valves when handling fuelinside the spherical enclosure and (2)

DTS 3/4.1.1.d, Action iv, that requires immediate action to provide for alternate radiation monitoring of radiation levels either by an instrument that alarms locally and remotely or by personnel continuously monitoring radiation levels and in communication with the Monitoring Station. The staff notes that the proposed changes provide adequate assurance that plant staff willidentify off-normal radiation conditions in the vicinity of the SFP and take appropriate action to monitor and r,orrect the situation. Further, the deletion of the automatic closure feature associated with the containment isolation valves is consistent with the licensee's accident and radiological dose consequence evaluations that j did not take credit for containment. The staff finds the changes described above acceptable.

The licensee proposes to delete CTSs 6.4.3 and 6.4.4 which are associated with reactor water level monitors in the reactor depressurization system and containment pressure and water level monitoring systems. These systems are required for reactor operation and not applicable to the permanently shutdown and defueled condition of the facility. Further, there is no necessity to monitor containment pressure, since containment integrity is no longer required to assure public health and safety. The staff finds these changes acceptable.

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~ CTS SECTION 7, OPERATING PROCEDURES CTS 7.0 describes those " basic operating principles and procedural safeguards which have a potential effect on safety." These principles and safeguards are for normal and emergency operation, Phase 11 testing, and for operational testing of the nuclear safeguards systems of the plant. CTSs 7.1 through 7.2.3 were deleted by previous amendment. The licensee proposes to delete CTS 7.2.4 controis related to high performance fuel and CTS 7.3, " Normal Operation," relating to the requirement to have detailed operating procedures of each mode of plant operation, cold start-up, extended shutdown, hot start-up, normal power operation, extended shutdown, and short-duration shutdown. These requirements were for special reactor plant operation and are not applicable in the permanently shutdown and defueled condition. The staff finds these changes acceptable.

CTS 7.4, " Refueling Operation," requires detailed written procedures for refueling operation and requirements for the conduct for core refueling (CTS 7.4(a),. The other CTS requirements for core refueling include: (1) CTS 7.4(b), requirements for fuel movements in the reactor vessel; (2) CTS 7.4(c), reactor safety system trip devices, source range monitors, and neutron detectors; (3) CTS 7.4(d) procedures and controls for core alterations; (5) CTS 7.4(e), operability of the liquid poison system; (6) CTS 7.4(g),

unirradiated fuel storage requirements; and, (7) CTS 7.4(h), irradiated fuel and fuel channel storage requirements. CTSs 1.2.3 and 1.2.4 provide definitions for a refueling operation" and a " major refueling," respectively. These definitions are specifically written to be only applicable to fuel handling or other activities performed in the reactor vessel.

Therefore, the CTS 7.4(a) - (e), (g), and (h) requirements are no longer applicable, because the BRP reactor vesselis permanently shut down and defueled. Nonetheless, to ensure written procedures for fuel handling operations Consumers proposes DTS 6.6.1.1 as:

Written procedures shall be established, implemented and maintained for safety related structures, systems and components and safety actions defined in the Big Rock Point Decommissioning Quality List and those structures, systems, components and activities important to the safe storage of spent fuel (ISSSF) and monitoring and control of radiological hazards (IMCRH) These procedures shall meet or exceed the requirements of ANSI N16.7-1976, as endorsed by the Quality Program Description (CPC-2A).

Written procedures shall also be established implemented, and maintained covering the following activities:

a) Defueled Security Plan; b) Defueled Emergency Plan; c) Quality Program Description (CPC-2A); and, d) All programs listed in Specification 6.6.2.

4 0 To address the CTS 7.4(h) requirement that irradiated fuel be stored in the SFP, Consumers proposes DTS 3/4.1.3.a to require irradiated fuel to be stored in the fuel storage racks in the SFP. Consumers also proposes to delete CTS storage requirements for irradiated fuel channels. The staff notes that based on the four criteria in 10 CFR 50.36(c)(2)(ii), TS requirements for the storage of radioactive materials (excluding spent fuel) are not required. Further, the storage of radioactive material onsite would be in such a manner to maintain radiative exposures as low as reasonably achievable (ALARA) in accordance with 10 CFR Part 20. Therefore, there is reasonable assurance that storage of radioactive fuel channels will not result in conditions adverse to pubic health and safety. Regarding the liquid poison system, alternate reactor shutdown is no longer required because the reactor vesselis permanently defueled and proposed DTS requirements (DTSs 5.2.1 and 3/4.1.3) provide assurance that the spent fuel stored in the SFP will remain subcritical without the use of borated water. Further, as previously discussed, the licensee is precluded from storing "new" reactor fuel onsite. The staff finds the deletion of CTS (a) - (e), (g), and (h) and proposed changes DTSs 3/4.1.3.a, 3/4.2.1.a and 6.6.1.1 acceptable.

CTS 7.4(f) : ates that containment sphere integrity provisions shall be in effect during refueling o- ;tions. Thus, this CTS requirement is not applicable to the conduct of fuel handling o, ations in or about the SFP, as described above and as presented by Consume' , its letter dated July 21,1998 (page 52, question 90) that stated that refueling aru fuel handling are not synonymous and that only fuel handling activities are authorized at the BRP facility. Therefore, the containment integrity provision of CTS 7.4(f) is not applicable to current status of the BRP f acility. Nonetheless, as previously described, Consumers proposes to apply a containment closure concept (DTS 1.6) during fuel handling (DTS 3/4.2.1) and during the movement of heavy loads over the SFP (DTS 3/4.3.1) to provide additional assurance that these activities would not result in offsite radiological conditions adverse to public health and safety. The DTS Bases defines a heavy load "as 500 pounds (the weight of a fuel assembly and the handling equipment). Also, as previously evaluated, the worst-case fuel accident (a dropped fuel transfer cask onto the spent fuel racks) would not result in offsite doses in excess of EPA PAGs, even with no credit being provided for ventilation or containment.

The staff finds the proposed CTS 7.4(f) deletion and DTSs 1.6, 3/4.2.1.a, and 3/4.3.1.d acceptable.

CTS 7.4(i) requires that the " minimum refueling crew during refueling operations shall be four men. There shall be a licensed operator in the control room at all times, and the Shift

Supervisor (SS) shall be in charge." The licensee proposes to relocate and revise this CTS to make it applicable to the conduct of fuel handling operations in or about the SFP during decommissioning. As detailed in DTS 6.2.2.a and c. and DTS Table 6.2-1, " Minimum Shift Crew Composition During Permanently Defueled Condit!cn," the licensee proposes a l minimum shift crew and command and control organization for fuel handling applicable to l

the current condition of the BRP facility. Further, by letter dated April 16,1998, the NRC l approved the licensee's certified fuel handler (CFH) training program and by regulation (10 CFR Part 55) licensed-operators are no longer required at the .BRP facility, because 1

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l the plant is permanently shut down and defueled. The licensee proposes DTS 6.4,

! " Training," to provide adequate assurance that a training program for the BRP CFHs (DTS 6.2.2.(e)) meet the requirements and recommendation of Section 5.5 of l ANSI N18.1-1971, which is consistent with the requirements of CTSs 6.3.1 and 6.4.1 of CTS Section 10, " Administrative Controls."

Regarding the control room staffing for fuel handling operations (DTS Table 6.2-1), the l licensee proposes to maintain a command and control structure similar to that when the plant conducted refueling; however, Consumers proposes to reduce the facility staff size and change the organization commensurate with the reduced radiological risk associated  ;

with fuel handling following the permanent cessation of power operations and removal of  !

all fuel from the reactor vessel. The SS maintains overall shift command and control i responsibility (CTS 6.1.2 revised to DTS 6.1.3) and will be a qualified CFH instead of an I individual holding a Senior Reactor Operators (SRO) license (CTS Table 6.2-1 revised to DTS 6.2.2.f and DTS Table 6.2-1). Further, the licensee proposes that the SS will report l to an individual qualified as a CFH (DTS 6.2.2.g). The command and control structure required by DTS 6.2.2.g is equivalent to that required by CTS 6.3.4 that required the SS

j. to report to an Operations Manager who held a senior reactor operator (SRO) license.

Further, during fuel handling, a qualified control room watchstander (i.e., a licensed operator) is required to be in the control room during fuel handling operations (CTS 7.4(i) revised to DTS 6.2.2.b); a person qualified in radiation protection will be onsite (CTS 6.2.2.d revised to DTS 6.2.2.c); and, fuel handling operations are directly supervised by a CFH who has no other concurrent responsibilities (CTS 6.2.2.e revised to DTS 6.2.2.e). Consumers also proposes to app!y overtime controls (CTS 6.2.2.g) to the personnel performing fuel handling (CTS 6.2.2.g revised to DTS 6.2.2.d).

The staff notes that the proposed shift staffing and command and control requirements are commensurate with the safety significance of fuel handling during this period following the permanent cessation of power operations. As previously discussed the l radiological consequences of the worst-case fuel handling accident has markedly reduced since final plant shutdown on August 30,1997, predominately due to the radioactive decay of short-lived radioactive isotopes. In addition, the requirements for licensed operators (10 CFR Part 55) are no longer applicable because the licensee has submitted the 10 CFR 50.82(a)(1) certifications; however, trained and qualified Certified Fuel Handlers and control / monitoring station operators are required for facility command and control. Regarding radiation protection personnel, the CTS has only the requirement (CTS l

6.2.2.d) that an " individual qualified in radiation protection procedures be on site when fuel is in the reactor;" there is no CTS requirement for radiation protection coverage during other times. However, Consumers proposes radiation protection coverage in DTS 6.2.2.c and Table 6.2-1 for all periods of operation; in summary these DTSs require a qualified Radiation Protection Technician during periods of fuel handling and a radiation protection procedure-qualified Shift Supervisor or non-Certified Operator during periods without fuel i handling. These radiation protection staffing requirements provide assurance that trained i individuals are onsite to respond to normal and off-normal radiological conditions.

! Further,10 CFR Part 20 and proposed DTS 6.6.2.1 provide additional radiation protection requirements to minimize radiation exposure.

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l The staff notes that the specific TS description of a four-man crew (CTS 7.4(i)) does not directly contribute to safety and that requiring a minimum shift crew number for refueling l is not consistent with 10 CFR 50.36(c)(2)(ii) and the STS. Nonetheless, the licensee l

proposed (1) DTS 6.6.1.1 requiring that procedures be developed for activities important to the safe storage of spent fuel, which is consistent with CTS 7.4(a); (2) DTS 6.2.2.e l requiring that fuel handling be directly supervised by a Certified Fuel Handler, which is

' l consistent with the CTS 6.2.2.e requirement that all core alterations be supervised, in I part, by a licensed Senior Reactor Operator; and, (3) DTS Table 6.2-1 requiring shift l manning requirements, which are consistent with the shift manning requirements of CTS Table 6.2-1 considering the permanently shutdown and defueled condition of the facility.

The staff finds the proposed CTS 7.4(i) deletion and proposed fuel handling DTSs 6.6.2.a, b, c, d, e, f, g, Table 6.2-1, and DTS 6.4 acceptable. l l The licensee proposes to relocate CTS 7.4(j), functional. testing of the trip mechanism of the fuel transfer cask safety devise, to proposed DTS 3/4.3.1.c regarding the handling of heavy loads over the SFP, where a heavy load is defined in the DTS Bases as 500 pounds l

(the weight of a fuel assembly and the handling equipment). Further, this CTS was editorially revised to reflect the current shutdown' and defueled condition of the facility.

The staff notes that the proposed relocation of CTS 7.4(j) to DTS 3/4.3.1.c does not reduce TS requirements or margins to safety. Further, the phrase " functional testing" of CTS 7.4(j) is equivalent to the DTS 3/4.3.1.d phrase that the trip mechanism will "be operable prior to handling the cask" based on the licensee's proposed DTS 1.12 definition of " Operable-Operability." The licensee is still required to ensure that the trip mechanism )

can perform its intended safety function prior to handling the 24-ton fuel transfer cask over or in the SFP. Testing of the trip mechanism " prior to commencing refueling activities" as DTS 7.4(i) requires is no longer applicable due to the permanently shutdown and defueled condition of the facility. The staff finds these changes and DTS 3/4.3.1.c acceptable. l 1'

DTSs 7.5 and 7.5.1 through 7.5.6 were deleted previously during a prior license amendment.

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The licensee proposes to delete CTS 7.5.7 regarding fuel bundles in the core and maintenance of an adequate shutdown margin. This CTS refers to core refueling operations and is not applicable to the permanently shutdown and defueled condition of the BRP facility. The staff finds this change acceptable.

CTS 7.6, " Operational Testing of Nuclear Safeguards Systems," requires, in part, written procedures for the testing of plant components and safety systems. These components include, but are not limited to: containment sphere access airlocks leakage rate; control rod performance; liquid poison system; reactor scram circuits; containment sphere isolation trip circuits; emergency condenser trip circuits; control rod withdrawal permissives; refueling operation controls; calibration of emergency condenser vent monitors; and channel checks and/or calibrations of reactor level for reactor depressurization, steam drum safety valve position, containment high radiation ventilation I

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isolation, high range containment gamma monitors, air ejector offgas, and containment pressure and water level monitors. The licensee proposes to delete these requirements.

These systems are required for reactor operation and post-accident reactor operation DBAs and are not required for a permanently shutdown and defueled reactor plant.

CTS 7.6 also requires calibration and functional test of the stack gas and process liquid monitors. The licensee proposes to relocate the testing of the stack gas and process liquid monitors to its ODCM, The NRC staff finds the relocation of CTS 7.6 stack gas and liquid monitors to the licensee-controlled ODCM acceptable, based on the staff evaluation of licensee-proposed changes to CTS Section 13, " Radiological Effluent Technical Specifications (RETS)," described later in this Safety Evaluation. Lastly, CTS 7.6 requires surveillance test of the containment sphere isolation trip circuits. Although not specifically applicable during the current shutdown and defueled condition of the BRP facility, Consumers ensures that radioactive material can be controlled by previously-evaluated DTSs associated with containment closure (DTS 3/4.2.1.a). The staff finds the above changes to CTS 7.6 acceptable.

The licensee proposes to delete DPR-6 license condition 2.B.(2)(e) that requires, in part, a human factors analysis of the meter on the noble gas stack monitoring system. TS requirements associated with this monitor are CTSs 6.4.1.b,7.6, and Tables 13.1, 2, and 3 with associated LCOs. The DPR-6 condition was a one-time requirement that has since been accomplished by Consumers. Therefore, this license condition is no longer applicable. As described in Section 4.1 of this Safety Evaluation, the staff finds the deletion of license condition 2.B.(2)(e) acceptable. Staff evaluation of the licensee's proposed relocation of the stack gas monitoring system requirements to its ODCM is provided in this Safety Evaluation for DTS 6.6.2.5 and CTS Section 13.

CTS 7.6 also requires calibration of the area radiation monitoring system and CTS 6.4.2 (of CTS Section 6) establishes other requirements for operability of these monitors. As discussed earlier for CTS 6.4.2, the licensee pioposes to relocate and editorially revise, as necessary, this testing and operability requirement to proposed DTSs 3/4.1.1.d and 3/4.2.1.a and b. The editorial revision consisted of placing the CTS requirements in a format consistent with the format of the other sections of the DTS and that of STS. The NRC staff finds the licensee's proposed relocation and editorial revision of the CTS 7.6 area radiation rnonitoring requirement to DTSs 3/4.1.1.d and 3/4.2.1.a and b acceptable.

The licensee proposes to delete DPR-6 license condition 2.B.(2)(f) that requires, in part, calibration of the high range containment radiation monitors to within manufacturers tolerances. TS requirements associated with this monitor are CTSs 6.4.2, 6.9.3.c of CTS Section 10, and 7.6 with associated LCOs and surveillances. A:, discussed in this Safety Evaluation, the relocation of CTS requirements associated with this instrumentation to the licensee-controlled ODCM is acceptable. Further, as stated earlier, these monitors are no longer necessary for the BRP f acility because there are no longer any operating reactor-type DBAs that warrant the use of such monitoring equipment. Therefore, these license requirements are no longer applicable. The staff finds these changes acceptable.

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CTS SECTION 8, RESEARCH AND DEVELOPMENT PROGRAM This section was deleted previously during a prior license amendment.

CTS SECTION 9, INSERVICE INSPECTION AND TESTING CTSs 9.0 through 9.4 applies to the inservice inspection and testing of the reactor vessel and other ASME Code Class 1, Class 2, and Class 3 system components to ensure piping and component integrity. Table 3.1 of Revision 6 to the UFHSR designated the SFP, SFP cooling system, fire protection system, service water system, and other systems as ASME Code class components. Further, Table 2.2 of NUREG-1482, " Guidelines for Inservice Testing at Nuclear Power Plants," indicates that the SFP cooling, service water, and ventilation systems are typica!!y Code class systems. Therefore, CTS are consistent with regulatory guidance, in its September 19,1997, submittal, Consumers proposed to remove ISI/IST requirements from its TSs; however, the licensee provided no justification for its proposed change. By letter dated April 16,1998, the staff requested Consumers to justify this proposed change. In response to the staff's April 16,1998, request for additional information, Consumers acknowledged, in effect, that 10 CFR 50.55a was applicable to the BRP facility (see Consumers' letter dated July 21,1998). The licensee also proposed to correct Revision 7 of its UFHSR, which currently states that the inservice inspection program is no longer required at the BRP facility. Subsequently, in its October 14,1998, letter, the licensee proposed to relocate and revise its DTS to: (1) maintain the requirements of CTS 9.1 as DTS 6.6.2.10.a; CTS 9.2 as DTS 6.6.2.10.b; CTS 9.3.a, b, and c as DTS 6.6.2.10.c.1, 2, and 3, respectively; (2) delete the requirement (CTS 9.3.d) to monitor radiation-induced changes in the mechanical properties of the reactor vessel materials; and, (3) delete the requirement (CTS 9.3.e) to perform inservice and intergranular stress corrosion cracking inspection of piping as described in GL 88-01.

NUREG-1482 provides guidance as to how a licensee determines which components at its facility are within the scope of IS!/IST. Thus, Consumers may revise its program consistent with the Commission's rules and regulations and applicable NRC guidance.

Inservice testing and inspection at the BRP facility is inspectable and enforceable. The staff finds the changes and the relocation of CTS 9.0 to DTS 6.6.2.10 acceptable.

CTS SECTION 10, ADMINISTRATIVE CONTROLS CTS 6.1, " Responsibility," was editorially revised by Consumers to reflect the permanent shut down and defueled status of the facility. Specifically, the licensee proposes to change the title to " Responsibility and Authority" and add and define DTS 6.1.1, "Senict Nuclear Officer" to replace and modify CTS 6.2.1.c, which discusses the equivalent position of the Vice President - Nuclear Operations. Consumers also edited CTS 6.2.1.c to remove any reference to "overall plant nuclear safety" and changed the requirement that this individual "shall take any measure needed to ensure acceptable performance of i

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the staff in operating, maintaining and providing technical support to the plant" with the requirement that the Senior Nuclear Officer (SNO) shall be responsible for the overall operation, maintenance and decommissioning of the facility. The staff notes that there is no necessity to have a TS that requires the SNO to take action, because this individual is

. required to be responsible and this TS requirement is not consistent with the criteria of 10 CFR 50.36(c)(2)(ii). Further, the change in title is considered an editorial change and the deletion of reference to nuclear safety does not reduce any assurance that operations, maintenance, and decommissioning at the BRP facility will be conducted safely and in accordance with Commission rules and regulations. The staff notes that the BRP Quality Program Description describes additional requirements for the SNO. The staff finds the changes and deletions of CTS 6.1 and CTS 6.2.1.c and proposed DTS 6.1 and DTS 6.1.1 acceptable.

CTS 6.1.1 requires that the Plant Manager be responsible for overall plant operation and delegate in writing the succession to this responsibility during his absence. Consumers proposes to rename this individual as the Site General Manager, change the paragraph number to DTS 6.1.2, and add administrative latitude to proposed DTS 6.1.2 to broaden the delegation of this individual's authority to other individuals. The NRC staff finds the licensee's proposed changes acceptable and commensurate with the reduced offsite radiological risk associated with the permanently shutdown and defueled status of the plant.

CTS 6.1.2 describes the responsibilities of the SS. Consumers proposes to change this paragraph to DTS 6.1.3 while maintaining that the SS shall continue to be responsible for the shift command function and that the SS shall be qualified as a CFH.10 CFR Part 55 and 10 CFR 50.54(m) do not apply to a facility that is perrnanently shut down and defueled. Therefore, any reference to operator licenses is not applicable to the current status of the BRP facility. The CTS Table 6.2-1 requirement that the SS will hold a SRO license was replaced with a statement in DTS 6.1.3 that the SS "shall be filled by a Certified Fuel Handler." Further, the licensee proposes to remove CTS 6.1.2 reference to the requirement to have a management directive regarding the SS. The CTS 6.1.2 requirement to have a management directive is not necessary to assure public health and safety and the change from the requirement to have a SRO-licensed SS to one qualified as a CFH is commensurate with the reduced radiological risk at the BRP facility and in accordance with Commission requirements. The staff finds these changes acceptable.

CTS 6.2.1 was changed in title from "Offsite and Onsite Organizations" to " Organization" and the introductory paragraph was cdministratively revised to (1) replace "offsite" with

" corporate," (2) delete any reference to organizational positions; and, (3) add that the organization and corporate reporting relationship will be established for activities affecting safety of the facility. The staff finds these changes acceptable, because the BRP Quality i

Program Description describes the corporate organization and details positions responsible for plant safety, such as the Senior Nuclear Officer (CTS 6.1.1) and Site General Manager (CTS 6.1.2). Further staff evaluation of the Quality Program Description is provided below in staff review of licensee-proposed changes to CTS 6.5, " Review and Audit."

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CTS 6.2.1.a discusses and provides detail as to the administrative requirements for lines  !

of authority, responsibility and communication. Proposed DTS 6.2.1.a maintains that lines of authority, responsibility and communication shall be established; however, I

Consumers proposes to remove the information as to how this will be accomplished from l the CTS and relocate this requirement to licensee-controlled documents, such as its Quality Program Description (CPC-2A). This information includes the documenting, updating, and reporting of organization changes to the NRC and the documentation of these requirements in the UFHSR, CPC-2A, Nuclear Operations Department Standards, or l plant administrative procedures. The staff notes that 10 CFR 50.54(a) provides requirements for quality program changes, reporting requirements to the NRC, and NRC approval requirements. Thus, adequate regulatory requirements exist to ensure that licensee changes to its quality program are conducted properly with NRC review and approval, if required. Further, these types of CTS administrative requirements do not meet the 10 CFR 50.36(c)(2)(ii) criteria. The staff finds these changes acceptable.

CTS 6.2.1.b requires the Plant Manager to be responsible for overall plant safe operation and have control over those onsite activities necessary for safe operation and maintenance of the plant. Consumers maintains this requirement as DTS 6.2.1.b, changes the name

" Plant Manager" to " Site General Manager" (SGM), and adds that the SGM will report to the SNO (CTS 6.2.1.c and DTS 6.1.1). The staff finds these changes acceptable, because these changes do not reduce the effectiveness of the organization structure, l clarify the senior management positions associated with the BRP facility, and add a new l requirement that the SGM will report to the Senior Nuclear Officer, a corporate position i held by the Senior Vice President - Nuclear, Fossil, and Hydro Operations.

L CTS 6.2.1.d requires that individuals who train the operating staff and those who carry out health physics (HP) and quality assurance (QA) functions may report to the

appropriate onsite manager; however, the HP and QA personnel are required to have sufficient organizational freedom to ensure their independence from operating pressures.

Consumers proposes to replace CTS 6.2.1.d with DTS 6.2.1.c for QA personnel and DTS 6.2.1.d for persons who train the operating staff and those who carry out radiation protection functions. Specifically, DTS 6.2.1.c requires OA personnel to report to the

Maneger, Nuclear Performance Assessment Department, which is a corporate organization l independent of the onsite organization as described in the BRP Quality Program l Description; CTS 6.2.1.d did not specify who the QA personnel should report to. The l wording associated with radiation protection individuals was not changed. However,

! Consumers proposed to replace the phrase " operating staff" with " Certified Fuel Handlers" to reflect the permanently shutdown and defueled condition of the facility. The staff finds these changes acceptable, because they are consistent with 10 CFR 50.36(c)(6), they add specificity to the TSs, and do not reduce TS requirements, i

CTS 6.2.2, " Plant Staff" CTS 6.2.2, " Plant Staff," was revised to reflect the perrranently shutdown and defueled status of the f acility. As previously discussed, the licensee proposes changes associated i

i with plant staffing for 'uel handling and heavy load operations. The following discussion of the CTS 6.2.2 refers to plant activities and conditions in which fuel handling is not being conducted and supplements the discussions provided earlier for the requirements associated with the fuel handling staff.

The licensee proposes to change the title of CTS 6.2.2, " Plant Staff," to DTS 6.2.2,

" Facility Organization," and to add the introductory phase "[t]he facility organization shall be subject to the following." The staff finds these changes acceptable, because they are administrative and do not reduce TS requirements.

i in CTS 6.2.2.a, the word ." composed" was replaced with the word " comprised." In CTS 6.2.2.b, " licensed operator" was replaced with " individual ... qualified to stand watch," reference to fuel in the reactor was replaced with "when irradiated fuel is in the spent fuel pool," and " control room" was replaced with " Monitoring Station." As proposed by the licensee, the monitoring station (DTS 1.10) is "the facility which has monitoring, alarming, data archiving and limited control capabilities for selected system l parameters during the decommissioning process." As previously discussed, the

. requirement to have and maintain licensed operators is no longer required and revision to indicate that irradiated fuel is no longer stored or retained in the reactor is appropriate.

The licensee's proposal to change the name and description of the control room is considered administrative, in that the monitoring station is functionally and administratively equivalent to the control room. The monitoring station will continue to be the command and control center for facility activities and response to off- normal plant conditions. The monitoring station will also maintain alarm, indication, and communication equipment, as necessary, to support the safe decommissioning of the BRP

{ facility and spent fuel storage. Control room design features such as environmental qualification, habitability, and safeguards are no longer applicable due to the permanently shutdown and defueled status of the facility; however, the licensee still must ensure that the environmental conditions (such as, in part, radiation dose during normal and off-normal conditions) within the monitoring station are consistent with applicable rules and regulations (such as 10 CFR Part 20 and Appendix 1 to 10 CFR Part 50). Therefore, the change in name from control room to monitoring station is acceptable and the licensee must adequately justify and implement the facility modification, procedure change, and/or design change in accordance with 10 CFR 50.59 and license requirements. The staff finds the changes described above acceptable.

CTS 6.2.2.c, regarding licensed operators, and CTS 6.2.2.e, regarding core alterations, were deleted in their entirety. These TS requirements are only applicable during power reactor operations and core refueling activities. Therefore, as previously discussed, these requirements are not applicable during the permanently shutdown and defueled status of the BRP facility. The staff finds these changes acceptable.

) CTS 6.2.2.d requires that an individual qualified in radiation protection procedures be j onsite when fuel is in the reactor. Consumers proposes to (1) remove the phrase "when

fuelis in the reactor"and (2) change the CTS paragraph number to DTS 6.2.2.c. Further,

, Consumers proposes to replace and clarify the requirement that an " individual qualified in I

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l radiation protection procedures shall be on site when fuelis in the reactor" with the requirements that (1) a " qualified Radiation Protection Technician shall be onsite" during l

l fuel handling operations and (2) during " operations without fuel handling either the Shif t Supervisor or the Non-Certified Operator shall be qualified in radiation protection procedures." Therefore, the licensee clarifies that a Radiation Protection Technician is required to be onsite during fuel handling operations to provide reasonable assurance that adequate radiation protective measures will be taken during this activity and that, during l all other times, one person qualified in radiation protection procedures shall be onsite. The staff finds that the proposed changes are commensurate with the reduction of radiological risk at the facility and do not represent a net change in the level of radiation protection coverage; therefore, the changes are acceptable.

l CTS 6.2.2.f requires a minimum fire brigade size to assure the safe reactor shut down during plant operation and the maintenance of the reactor in a safe shutdown condition following power operation. This TS also requires that the minimum staff for the fire brigade could not include staff members required for safe reactor shut down and other

" essential functions." The licensee proposes to teloca+c CTS 6.2.2.f in its entirety to its fire protection program, a licensee-controlled document. During the permanently shutdown and defueled condition, the fire protection requirements of 10 CFR 50.48(a) through (e) and CTS 6.2.2.f are no longer applicable. Nonetheless, the licensee stated in its July 21,1998, letter that the BRP fire protection program will meet the requirements of 10 CFR 50.48(f) that requires decommissioning licensees to maintain a fire protection t

program to preclude the release or spread of radioactive materials. The objectives of this program are, in part, to: (1) reasonably prevent the fires from occurring; (2) rapidly detect, control, and extinguish fires; and, (3) minimize the fire-induced risk of radiological hazards. 10 CFR 50.48(f) also requires the program to be periodically assessed and revised as appropriate to reflect plant conditions. Further, Consumers stated in its letter that there was a one-to-one correlation between the CTS and the UFHSR, Revision 7, confirming that the facility fire protection requirements were appropriately transferred to its licensee-controlled document.

Regarding the removal of the requirement to staff a 5-member fire brigade from the CTSs and associated quarterly training drills, the NRC staff notes that these CTS requirements were established, in part, to meet the requirements of 10 CFR Part 50, Appendix A, Criterion 3, and 10 CFR 50, Appendix R, Section 11, Subsection H " Fire Brigade," as l required by 10 CFR 50.48(a) and (b), respectively. As stated in subsection H of l Appendix R, the fire brigade must ensure adequate manual fire fighting capability for all areas of the plant containing structures, systems, or components important to safety.

The requirements of Appendix R are no longer applicable to the permanently shutdown and defueled BRP facility. Further,10 CFR 50.48(f) requires, in part, that the decommissioning fire protection program must ensure, in part, that fires are rapidly extinguished and that the risk of fire-induced radiological hazards to the public, environment and plant personnelis minimized. The licensee currently plans to meet the l

requirements of 10 CFR 50.48(f) by implementing a 3-member fire brigade (as currently proposed) and establishing monthly shift fire drills and individual drill requirements (as

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'describal in the BRP fire protection program) to provide reasonable assurance that the

' brigade can perform its intended function. Additionally, DTS 6.2.2.b requires at least one i

individual qualified to stand watch in the monitoring station shall be in the monitoring

l. - station when irradiated fuel is in the spent fuel pool. This qualified individual has the

- capability to summon onsite and offsite fire response personnel. Further, CTSs 3.3.3.8 L through 3.7.12 of CTS Section 12, " Instrumentation,' mcluding the associated Bases and i surveillaa<:e requirements, requires fire detection equipment, suppression and sprinkler l

systems, hose stations, and btrriers be maintained. The licensee's proposed amendment request does not propose revision or removal of these requirements.

i 10 CFR 50.48(f) allows licensees to make changes to their fire protection programs l' without NRC staff approval, if the changes do not reduce the effectiveness of fire protection for the facility, systems, and equipment which could result in a radiological

! hazard. Based on the current status of the BRP facility, the change of fire brigade size l and periodic training requirements is consistent with the regulatory requirements

! associated with a permanently shutdown and defueled power facility and the reduction in the number and complexity of SSCs and radiological sources that could result in radiological hazards. Further, these changes (1) are consistent with the guidance provided i in GL 86-10 and 88-12; (2) maintain adequate assurance that fire program objectives, as l - described in 10 CFR 50.48(f), can and will be met; and, (3) are inspectable and

enforceable. The staff finds the relocation of CTS 6.2.2.f and CTSs 3/4.3.3.8 through l 3/4.7.12, including the associated surveillance requirements and tables to licensee-controlled documents, such as the UFHSR or BRP fire protection program,

! acceptable.

CTS 6.2.2.g involves administrative procedures to limit working hours of plant staff who perform safety-related functions. The licensee proposes to maintain overtime limits for its plant personnel; however, Consumers proposes changes to reflect the permanently

, shutdown and defueled conditions of the plart. Specifically, the applicability of overtime

! controls to staff who perform _" safety-related operat5n functions" was replaced with j staff who perform " safety-related functions, and activities important to the safe storage of spent fuel (ISSSF) and the monitoring and control of radiological hazards (IMCRH)."

The CTS 6.2.2.g phrase "i.e., senior reactor operators, reactor operators, auxiliary I

operators, health physicists and key maintenance personnel" was replaced with "the minimum shift crew required by Table 6.2-1, key maintenance personnel and Radiation Protection Technicians." Further, the licensee proposes to: (1) delete CTS 6.2.2.g(4) regarding overtime use during extended shutdown periods; (2) delete the requirement the deviations shall L s authorized by " higher ~ levels of Management," (3) replace " Plant l Manager" with " Site General Manager;" (4) add the word " administrative" prior to the j word " procedures;" (5) combine the two paragraphs located immediately after CTS 6.2.2.g(4) into one paragraph located immediately after DTS 6.2.2.d(3); and, (5) maintain that individual overtime be reviewed on a monthly basis. The staff notes that

, the licensee-proposed changes do not reduce the requirements that overtime will be properly controlled and reviewed by responsible individuals. This maintains the assurance j' that personnel conducting activities that have the potential of adversely impacting safety v

+tTJ** * - - + f +--"Y- 7 - W "

have work schedu'es that facilitate periods of rest. Further, the Consumers' proposal to apply overtime controls to activities ISSSF and IMCRH represents an increase in l applicability of this requ!rement beyond that required by the CTS. Further, the change associated with " higher levels of Management" removed ambiguity and improved specificity without reducing overtime control. DTSs 6.2.2.g.(1) and (2) remain unchanged. The staff finds these changes acceptable.

CTS Table 6.2-1, " Minimum Shift Crew Composition, was changed to reflect the permanently shutdown and defueled condition of the BRP facility. The licensee proposes to: (1) add to the title of Table 6.2-1 the wording "During Permanently Defueled Condition;" (2) delete reference to " Power Operations," " Refueling Operations," and

" Shutdown or Cold Shutdown;" (3) delete the minimum shift staffing composition associated with the different modes of reactor operation; (4) delete the definitions for "SS," "RO," and "AO;" (5) delete reference to licensed and non-licensed operators; (6) add minimum staffing requirements for operations with and without fuel handling; (7) designate the SS as being a qualified CFH; (8) replace the Auxiliary Operator with a non-certified operator and the Reactor Operator with a individual qualified as a CFR; and (9) add staffing requirements for a Radiation Protection Technician during fuel handling and a individual qualified in radiation protection procedures during operations without fuel handling. The licensee also rnade editorial changes. However, as previously discussed, CTS 6.2.2.a and CTS Table 6.2-1 do not require nor provide a minimum on-duty shift for fuel handling in the SFP. Nonetheless, Consumers proposes changes to this TS to address fuel handling in the SFP and decommissioning activities to provide reasonable assurance that facility activities will be conducted safely, in addition, based on the significant reduction in the number and complexity of SSCs required during tne permanently shutdown and defueled condition, the types and radiological severity of DBAs, and the reduction in radiological source term from the spent fuel gap and LLRW, the possibility of normal or off-normal situations resulting in offsite conditions adverse to public health and safety is extremely lo.v. Further, following certification of permanent reactor shutdown l

and removal of all fuel from the reactor vessel, the requirements of 10 CFR 50.54(i-1),

(j), (k), (I), and (m) and 10 CFR Part 55 no longer apply. Based on the above. W proposed changes are commensurate with safety. The staff finds these cha-acceptable.

CTS 6.2.2, last paragraph, provides allowance for shift staffing to be "one individual less than the minimum requirements of ICTS] Table 6.2-1 for a period of time not to exceed 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in ordar to accommodate unexpected absence of on-duty shift crew members provideo immediate action is taken to restore the shif t crew composition." This allowance is also afforded to the individual qualified in radiation protection procedures (CTS 6.2.2.d) and the fire brigade (CTS 6.2.2.f) by reference to the footnote on CTS page 72. The licensee proposes to (1) maintain CTS 6.2.2, last paragraph, as CTS 6.2.2.h; (2) delete any reference to the fire brigade: (3) delete reference to the on-call Technical Advisor (Jee below discussion on the Technical Advisor), and (4) delete the requirement that during "any absence of the Shift Supervisor from the control room during power operation and individual with a Reactor Operators License shall be designated to assume the control

a ,

room command function." Consumers also proposes to maintain requirements that (1) limit this time to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />; (2) ensure that immediate actions are taken to restore the minimum requirements specified; (3) apply the minimum staffing requirement to  !

unexpected absence of on-duty personnel; and, (4) specify that these requirements do not apply to any on-coming shift crew member being late or absent. Editorial changes were also proposed. The staff notes that the removal of any reference to minimum fire brigade staffing is consistent with 120 CFR 50.36(c)(2)(ii) and (c)(6) and that the requirements for fire brigade staffing (5 members maintained onsite at all times) and the provision for less than minimal staffing (not to exceed two hours to accommodate unexpected absence) are maintained and described in UFHSR Chapte.- 9.5.1.4, " Fire Brigade." As previously described, the relocation of fire protection TSs to a licensee-controlled document such as the UFHSR or BRP fire protection plan is acceptable. Also, the staff notes that the editorial changes did not result in a net reduction of requirements. The staff finds these changes acceptable.

CTS 6.3, " Plant Staff Qualifications" The licensee proposes to changs the title for CTS 6.3, " Plant Staff Qualifications" to

" Staff Qualifications" and delete (1) CTS 6.3 subparagraph numbers 6.3.1 through 6.3.4; (2) the titles " Chemistry and Health Physics Manager or the Radiation Protection Supervisor" (CTS 6.3.2), "On-call Technical Advisor" (CTS 6.3.3, see below discussion) and the " Operations Manager" (CTS 6.3.4); and, (3) the requirement that the Operations Manager shall hold a SRO license and shall direct the activities of licensed operators. As a replacement, Consumers proposes (1) that *(elach member of the facility management and supervisory staff shall meet the minimum requirements of ANSI N18.1-1971 for comparable positions;" (2) that the " individual responsible for radiation protection functions shall meet the minimum requirements of Regulatory Guide 1.8, September, 1975;" and, (3) the following footnote 1 oa DTS page 6-4, which incorporates proposed editorial changes to Footnote 1 on CTS page 74:

l As applied to this specification, " equivalent," as used in Regulatory Guide 1.8 for the bachelor's degree requirement, may be met with four years of any one or combination of the following: (a) formal training in science engineering or (b) operational or technical experience and training in nuclear power.

The editorial changes to Footnote 1 were to change the word " Formal" to lower case and separate the phrase " experience / training" to " experience and training." The combining of the CTS 6.3 paragraphs (specifical;y the deletion of the CTS paragraph numbers) into one l paragraph under DTS 6.3 was administrative. CTS deteil as to the titles of various BRP l chemistry and radiation protection individuals are not necessary to assure safety and compliance, because the ANSI standard and RG provides appropriate qualification requirements for applicable organizational positions. The proposed changes also reflect the status of the BRP facility and the removal of titles also deletes unnecessary specificity and enhances the reference to positions described in RG 1.8. Therefore, qualification requirements for plant management and supervisory staff have not changed.

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Regarding the removal of the position titles of CTSs G.3.2, the basis for RG 1.8 is 10 CFR Parts 50 and 55. In particular,50.34(b)(6)(i) requires that an application for a license to operate a nuclear power plant include information concerning, in part, personnel qualifications. Subpart D, " Applications," of 10 CFR Part 55, " Operator's Licenses,"

requires that operator license applications include information concerning an individual's education and experience and related matters. RG 1.8 describes a method acceptable to the NRC staff for complying with these portions of the Commission's regulations, which focus on licensing and operation of a power reactor. The deletion of any CTS reference to the site-specific position titles (" Chemistry and Health Physics Manager or the Radiation Protection Supervisor") is acceptable, in part, because this type of organization detail will be contained in other licensee-controlled documents, such as CPC-2A, and RG 1.8 and ANSI /ANS N18.1-1971, describing the organization positions and qualifications applicable i to a facility. Further, UFHSR Chapter 13.1, " Organizational Structure," provides '

plant-specific positions and titles assocbted with the BRP facility. Specifically, Chapter 13.1.3 describes that either the Radiation Protection and Environmental Services Manager ,

or Radiation Protection Supervisor will meet or exceed the qualification requirements of RG l 1.8, September 1975, and that staff qualifications will be established and consistent with ANSI N18.1-1971. Thir 'JFHSR chapter further describes that these qualifications will be in the job position matrix maintained by the Consumers /BRP human resources department.

Regarding the Technical Advisor, Consumers proposes to delete CTS requirements associated with this position (CTS 6.3.3 and CTS Table 6.2-1, " Minimum Shift Crew Composition"). The Technical Advisor position originated, in part, following the March 1979, Three Mile Island Unit 1 accident (as described in NUREG-0578 and NUREG-0737, l.A.1.1) to provide on-shif t engineering and accident assessment advice to the SS in the event of abnormal or accident conditions. NRC Policy Statement on Engineering Expertise on Shift, dated October 28,1985, provides additional clarification that the shif t technical advisor aids the operating staff and may be combined with a SRO position to meet licensed-operator staffing requirements of 10 CFR 50.54(m), The NRC staff notes that 10 CFR 50.54(m) is not applicable to a Part 50 licensee that has certified permanent cessation of power operation and removal of all reactor fuel from the reactor vessel. Also, the number and severity of DBAs associated with a defueled and permanently shutdown facility are less than those of an operating, hot or cold shutdown, or refueling power reactor. The severity of these DBAs also contiriues to decrease as the irradiated fuel ages. Further, in the permanently shutdown and defueled condition, there i is a lack of motive force to propel a radiological release to the environment and the j engineered features associated with spent fuel storage (to preclude criticality, abnormal l

radiation conditions, and unintended radiological releases) continue to exist. Therefore, the CTS requirements regarding the Technical Advisor are not necessary to satisfy regulatory requirements or to provide reasonable assurance that facility operations can and will be conducted safely.

Based on the above, the staff finds the CTS changes and DTSs 6.3,6.2.2, and 6.6.2.9 acceptable.

I I

' CTS 6.4, "Trainina" )

The licensee prvposes to

(1) delete CTS 6.4, subparagraph numbers 6.4.1 and 6.4.2, l and reference to 10 CFR 55; (2) replace " plant staff" with " Certified Fuel Handlers;" (3) move CTS 6.4.2 training requirements for the fire brigade to the licensee-controlled BRP fire protection plan or UFHSR; and, (5) combine the two CTS paragraphs into one. The licensee maintains that the CFHs will meet the requirements and recommendations of l Section 5.5 of ANSI N18.1-1971. Regarding the proposed changed fire brigade training  !

requirements, Consumers stated in its July 21,.1998, letter that a one-to-one correlation i exists between CTS fire protection requirements and 'the fire brigade requirements ,

maintained in licensee-controlled documents,'such as the UFHSR and BRP fire protection I plan. Further, Consumers stated that they will continue to meet 10 CFR 50.48(f) I requirements for facilities that have submitted the certifications requ; red under 10  !

CFR 50.82(a)(1) and proposed DTS 6.6.2.7, " Fire Protection Program," stating that a " fire protection program meeting the requirements of 10 CFR 50.48(f) shall be established, implemented, and maintained." The operator training program requirement now specifically focuses on the training of Certified Fuel Handlers, instead of the more general  ;

phrase " plant staff," as previously required. This change provides assurance that the plant staff (as described in DTS 6.2.2) who are responsible for the storage, control, and maintenance of spent fuel are properly trained. Also, additional assurance is provided by i 10 CFR 50.120, " Training and qualification of nuclear power plant personnel," which I establishes training program requirements for instrument and controls technicians, electrical and mechanical maintenance personnel, radiological protection technicians, and others. Removal of the phrase " retraining and replacement" is administrative, in that the NRC-approved CFH training program includes appropriate reqv;rements for the retraining l and replacement of CFHs. Therefore, there is no net reduction in regulatory requirements.  ;

Based on the above, the staff finds the changes to CTS 6.4 and DTSs 6.4 and 6.6.2.7 l acceptable.

Quality Assurance By letters dated September 19,1997, June 5, July 21, and October 14,1998, Consumers proposed, in part, (1) removal of quality assurance-related (QAR) requirements to licensee-controlled documents, namely CPC-2A, the Quality Program Description (QPD) and (2) revision or editorial change of other QAR requirements currently located in the CTS. Consumers relocated CTS QAR requirements to its OPD using the information and guidance provided in NRC Administrative Letter (AL) 95-06, " Relocation of Technical Specifications Administrative Controls Related to Quality Assurance," dated December 12, 1995. By letters dated October 10,1997, and July 27,1998, the licensee submitted two proposed changes (Revisions 19a and 19b) to its QPD detailing its intent to change its quality assurance (QA) program to account for the permanently shutdown and defuekd

! status of the BRP facility and to reflect the changes the licensee proposes for its DTS.

4 l The following QA evaluation addresses: (1) the conformance of the proposed administrative controls section of CTS 6.8/DTS 6.6.1, " Procedures" to the content  ;

1 l specified in NUREG-1431, Revision 1, and to the requirements of 10 CFR 50.36(c)(6); (2)

I the proposed re!ocation of QAR requirements (CTS 6.5, " Review and Audit, " CTS 6.8.3,

" Temporary Changes to Procedures," and CTS 6.10, " Record Retention") from the CTS to the OPD in accordance with 10 CFR 50.36 (60 FR 36957) which, once relocated to the QPD and controlled pursuant to 10 CFR 50.54(a), would constitute the bases for the licensee's continued compliance with the requirements of Appendix B to 10 CFR Part 50; and, (3) the confirmation that Revision 19b to the QPD, dated July 27,1998, continues to comply with the criteria of Appendix B to 10 CFR Part 50.

As previously stated in this Safety Evaluation, regulatory requirements related to the content of TS are set forth in 10 CFR 50.36. That regulation requires that the TS include items in five specific categories, one of which is administrative controls (CTS Section 10).

10 CFR 50.36 also provides four criteria to be used in determining whether particular safety functions are requi ed to be included in the TS. While the four criteria specifically apply to LCOs, in adopting the revision to the rule the Commission indicated that the intent of these criteria can be utilized to identify the optimum set of administrative controls in the TS (60 FR 36957).

10 CFR 50.36(c)(5) states that administrative controls "are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure safe operation of the facility in a safe manner." Further, 10 CFR 50.36(c)(6) states that for licensees that hava submitted certifications required by 10 CFR 50.82(a)(1), TSs " involving safety limits... and administrative controls will be developed on a case-by-case basis." The specific content of the administrative controls section of the TS in therefore that information that the Commission deems essential for the safe operatic- I the facility that is not already adequately covered by other regulations. Accordingly, the staff has determined that requirements that are not specifically required under 10 CFR 50.36(c)(6) and that are not otherwise necessary to obviate the possibility of an abnormal situation or event giving rise to an immediate threat to the public health and safety, can be removed from administrative controls. Existing TS requirements, therefore, may be relocated to other documents (e.g. Security Plan, QA Plan, and Emergency Plan) and controlled by the applicable regulatory requirement.

Consumers states in OPD Section 2.2.6 that the provisions of its OPD apply to activities affecting the quality of BRP SSCs and related consumables selected according to the criteria below.

(1) SSCs based on engineering evaluation that uses the guidance of RGs 1.26 and 1.29 to determine those items whose function is important to safe plant operation and shut down. These items are commonly referred to as safety-related; (2) SSCs and activities important to the safe storage, control and maintenance of spent nuclear fuel (ISSSF); and, (3) SSCs and activities important to the monitoring and control of radiological hazards (IMCRH).

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l The extent to which controls specified in the OPD are applied is determined for each item considering its relative importance to the above criteria. Such determinations are based on data in such documents as the plant safety analysis, TS, and UFHSR. The revised administrative controls in the QPD also contain several editorial changes that reflect the permanently shutdown and defueled status of BRP facility.

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The licensee proposes that the review and audit functions in CTS 6.5 be relocated to the QPD such that future changes could be made pursuant to 10 CFR 50.54(a).

Section 13.4, " Operational Review," of NUREG-0800, " Standard Review Plan," provides the acceptance criteria used by the staff to evaluate TS provisions related to the plant j staff review of operational activities performed by licensee organizational units fulfilling j the review and audit function. This acceptance criterion is based on meeting the relevant l requirements of 10 CFR 50.40(b) as it relates to the licensee being technically qualified to

) engage in licensed activities and of Appendix B to 10 CFR Part 50 as it relates to the review and audit functions required by its QA program. Therefore, TS provisions associated with the review and audit function satisfies the criteria in both 10 l CFR 50.36(c)(6) and Appendix B to 10 CFR Part 50. As stated above, however, these provisions do not satisfy the current criteria for inclusion in TS and can be relocated to the licensee's QPD. Additionally, the following considerations support relocating these items l from the TS:

(1) The licensee proposes that the Palisades Plant Review Committee (PRC) and BRP Review Committee (SRC) function, membership, qualifications, meeting frequency, quorum . sponsibilities, authority, and records provisions be relocated with modifichuons to Appendix B, " Plant Review Committee (PRC) (Palisades)/ Safety Review Committee (SRC) (Big Rock Point)," of Revisions 19a and 19b to the QPD.

The modifications are reductions to previous TS commitments; however, these modifications do not represent a net reduction because they reflect the decommissioning status of the BRP facility. The SRC performs the onsite review function for BRP. The composition of the BRP SRC is reduced from nine members to four members and a Chairman. This five member SRC is required to meet or exceed the minimum qualifications described in Sections 4.2 and 4.4 of ANSI N18.1 -1971 for compt,raNe positions.

l Big Rock Point commits to RG 1.33, Revision 2, which conditionally endorses ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants," as one acceptable way to meet Criterion 11 of 10 CFR Part 50, Appendix B. ANSI N18.7-1976 does not specify a particular staffing level necessary to fulfill the onsite review function. A permanently defueled plant has a significantly reduced number of safety-related SSCs and activities as compared to an operational plant. Therefore, the proposed reduction in SRC membership to five persons is an appropriate level of staffing for a permanently shutdown and defueled plant and does not represent a net reduction in oversight. Further, this change in commitment is acceptable, because it is commensurate with safety. Subsequent changes associated with the PRC/SRC requirements will be controlled under 10 CFR 50.54(a).

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l (2) The licensee proposes that the BRP Independent Safety Review Group (ISRG) {

membership, meeting freque'ncy, quorum, responsibilities, authority, records, and I procedure provisions be relocated with new commitments or editorial changes to Appendix C, " Independent Safety Review," of Revisions 19a and 19b to the OPD.

The changes are not reductions in commitment and reflect the permanently

l shutdown and defueled status of BRP. Subsequent changes associated with the 1 ISRG requirements will be controlled under 10 CFR 50.54(a).

(3) The licensee proposes that the BRP audit provisions be reiocated with only new commitments or editorial changes to Appendix D, " Audit Frequencies," of l

Revisions 19a and 19b to the OPD. The changes are not reductions in

! commitment and reflect the permanently shutdown and defueled status of BRP.

Subsequent changes associated with the audit requirements will be controlled under 10 CFR 50.54(a).

f. The above approach is consistent with NRC AL 95-06. This approach also results in an equivalent level of regulatory authority while providing for a more appropriate licensee change control process. On this b. asis, the staff concludes that the review and audit functions identified above are not required to be included in the proposed DTS to protect the public health and safety and may be relocated to the QPD.

The following are CTS 6.8, " Procedures," requirements that Consumers proposes to change and/or relocate to its OPD:

(1) The licensee proposes to relocate with only new commitments or editorial changes CTS 6.8.1, " Procedures," to DTS 6.6, " Procedures and Programs." DTS 6.6

, includes procedural requirements for safety-related SSCs and safetv actions l defined in the BRP Decommissioning Quality List and those SSCs arid activities that are ISSSF and/or IMCRH.

l (2) The licensee proposes to relocate with only editorial changes CTS 6.8.2,

! " Procedures - PRC ResponsitWties," to Appendix B, " Plant Review Committee (PRC) (Palisades)/ Safety Review Committee (SRC) (Big Rock Point)," Section B6(a),

"SRC-Responsibilities" of Revisions 19a and 19b to the OPD. Subsequent changes associated with procedural requirements will be controlled under I 10 CFR 50.54(a).

(3) The licensee proposes to relocate with only editorial changes CTS 6.8.3, I

" Procedures - Temporary Changes" to Appendix A, Part 2, " Consumers Energy

! Exceptions to Operating Phase Standards and Regulatory Guides" Section 2h(c) of Revisions 19a and 19b to the QPD. Subsequent changes associated with the temporary change requirements will be controlled under 10 CFR 50.54(a).

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Based on the above, the staff finds that the recuirements of DTS 6.6 remain consistent with those of the CTS and that the relocation of CTS 6.8 procedural requirements is acceptable.

The licensee proposes to relocate with changes the record retention requirements in CTS 6.10, " Record Retention," to OPD, Appendix E, " Record Retention." The changes reflect the permanently shutdown and defueled status of BRP and meet the requirements of 10 CFR 50.36(c)(6). The proposed changes are not a reduction in commitment.

l Further, once relocated to the QPD, these record retention requirements are controlled by 10 CFR 50.54(a). Additionally, Consumers relies upon its commitments to ANSI N18.7-1976 and ANSI N45.2.9-1974, " Requirements for Collection, Storage and 1 Maintenance of Quality Assurance Records for Nuclear Power Plants," (as endorsed by RG 1.88, " Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records," Revision 2) to satisfy the regulatory requirements of 10 CFR Part 50, Appendix B, Criteria XVil, " Quality Assurance Records."

Changes to the record retention provisions in the OPD are made pursuant to 10 CFR 50.54(a). In addition, other regulations such as 10 CFR Pm 20, Subpart L, and 10 CFR 50.71 require the retention of certain records related to operation of the nuclear plant. On this basis, the staff concludes that these regulatory requirements provide control of these record keeping provisions and removal from the CTS is acceptable.

The licensee proposes that the requirements related to the Emergency Plan and Security Plan contained in the CTSs 6.5.1.6.i, 6.5.2.1.j, and 6.5.2.4.2.d-e be relocated to Appendices B, C, and D of Revisions 19a and 19b to the OPD. The Emergency Plan and Security Plan requiroments would continue to be controlled by 10 CFR 50.54(q) and (t) and 50.54(p), respectively. The relocation is in accorc'ance with GL 93-07, " Modification of the Technical Specification Administrative Control Requirements for Emergency and Security Plans" and is acceptable to the staff.

The staff has evaluated the licensee's proposed CTS, OPD, and proposed DTS related to the OAR requirements and controls to NUREG-1431, Revision 1, and other guidance as described above. Based on this evaluation, the staff has concluded that: (1) the proposed DTS 6.6, " Procedures and Programs," conforms to the format and content specified in NUREG-1431, Revision 1, and to the requirements of 10 CFR 50.36(c)(6); (2) the proposed relocation of QAR administrative controls (CTS 6.5, " Review and Audit,"

CTS 6.8.3, " Temporary Changes to Procedures," and CTS 6.10, " Records Retention")

from the CTS to the OPD satisfies AL 95-06 provisions and 10 CFR 50.36 requirements and, once relocated to the OPD and controlled pursuant tc.10 CFR 50.54(a), constitute the bases for the licensee's continued compliance with the requirements of Appendix B to 10 CFR Part 50; and, (3) Revisions 19b (Revision 19 upon NRC approval) to the OPD, l dated July 27,1998, continues to comply with the criteria of Appendix B to 10 CFR l Part 50 in accordance with NUREG-0800 (SRP Sections 13.4 and 17.2).

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Therefor'e, the requirements related to the administrative controls described above which the licensee proposes be relocated, deleted, or changed are not required to be in the CTS /DTS under 10 CFR 50.36 or Section 182a of the Atomic Energy Act, and are not required to obviate the possibility of an abnormal situation or event giving rise to an immediato threat to public health and safety.

Regarding emergency planning, the licensee proposes to delete DPR-6 condition 2.B.(2)(g) that requires, in part, licensee notification of " State and local planning authorities of ...

whether there are practical means of expediting an evacuation ... [of a] major event at the Castle Farms site." There are no CTS requirements associated with this license condition.

Additionally, this DPR-6 condition was a one-time condition that has been accomplished by Consumers and on September 30,1998, the Commission determined that, pursuant to 10 CFR 50.12, elimination of offsite emergency planning activities will not present undue risk to public health and safety and is consistent with common defense and security. This conclusion was reached, in part, because the postulated dose to the general public from any reasonably conceivable accident would not exceed EPA PAGs. As a result, the implementation of immediate offsite protective measures is not necessary, considering the current shutdown and defueled condition of the facility. Therefore, this license condition is no longer applicable. The staff finds this deletion acceptable.

CTS 6.7, "Safetv Limit Violation" CTS 6.7, " Safety Limit Violation," describes actions to be taken in the event a safety limit is violated. These actions include reactor shutdown (CTS 6.7.1(a)), immediata notification to the NRC (CTS 6.7.1(b)) and a written report in accordance with CTS 6.9 and 10 CFR 50.36 (CTS 6.7.1(c) and (d)). CTS 6.9 provides information as to where the Safety Limit Violation report is required to be sent. 10 CFR 50.36(c)(1)(i)(A) states that

"[slafety limits for nuclear reactors are limits upon important process variables that are found to be necessary to reasonably protect the integrity of certain of the phyical barriers that guard against the uncontrolled release of radioactivity." Further, this regulation requires, in part, that upon exceeding any safety limit, "the reactor must be shutdown..."

and the " licensee -hall notify the Commission, review the matter, and record the results of the review, incit, . .g the cause of the condition and the basis for corrective action taken to preclude recurrence. Operation must not resume until authorized by the Commission."

CTS 4.1.1.i.(5) states, in part that " reactor water level shall not be permitted to decrease below the reactor water level setpoint at which reactor safety systems are actuated (Section 6.1.2) whenever fuelis in the reactor vessel." As stated by Consumers in its June 5,1998, letter to the Commission, this safety limit is no longer applicable to the BRP facility in its permanently shutdown and defueled condition.

Further, as previously described in this Safety Evaluation, in its letter dated November 12, 1997, Consumers calculated that a release of all spent fuel gap activity into the environment from a hypothetical 500 spent fuel assemblies (assuming no credit for ventilation and the spherical enclosure) would result in an offsite radiological dose less

L i 1 l

l l than EPA PAGs, a significant fraction below 10 CFR Part 100 reactor siting criteria. The i

licensee has also determined that there is no DBA that would result in conditions adverse  !

to public health and safety, because there is no credible mechanism that could separate '

and propel a sufficient quantity of radioactive isotopes from the spent fuelinto the j environment. Nonetheless, as described in its letter dated June 5,1998, Consumers l " recognizes the importance of ensuring the integrity of the spent fuel clad in preventing the uncontrolled release of radioactivity" and proposes that its DTS identify process variables that, if appropriately controlled and maintained, will provide further assurance (

f that licensed activities at the BRP facility will not be inimical to public health and safety.

L . The staff notes that these' process variables include: DTS 3/4.1.1 for SFP water l

chemistry, level, and temperature; DTS 3/4.1.2 for adequate SFP make-up water capability and redundant electrical power supplies; and, DTS 3/4.1.3 for spent fuel storage, in addition, the licensee provides defense-in-depth with DTS 3/4.2.2 for fuel handling and DTS 3/4.3.1 for heavy load handling over the SFP, and design features DTS l- 5.2.1 for spent fuel criticality, DTS 5.2.2 for SFP water level, DTS 5.2.3 for spent fuel

) cooling, and DTS 5.2.4 for SFP capacity.

DTS 3/4.1.1.a establishes SFP water level at or above the 630 feet level. This level ensures 22 feet of water is maintained above the active fuel, which is an assumption used in the fuel transfer cask drop analysis. This DTS corresponds to proposed DTS 5.2.2,

" Water Level," which states that the SFP is designed to maintain a normal water level between 630' and 632'6". As describes in UFHSR Chapter 9.1.2.1, SFP water level indication is provided by a sight glass on the SFP surge tank, direct visual observation, and a water level monitor with $ emote readout in the control room that can be powered from a diesel generator in the event offsite power is lost. Further, the licensee proposes that if SFP level is below the proposed level that activities that have the potential of draining the SFP will be immediately stopped, fuel and the crane load will be placed in a safe condition, movements of fuel or loads over the SFP will be suspended, and actions will be taken to restore water level. If SFP water cannot be restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,

{ containment closure will be set.

l-DTS 3/4.1.1.b establishes a SFP water temperature band of greater than 40 *F and less than 140 'F. These temperatures provide an appropriate margin between freezing (32 *F) and the onset of concrete degradation at temperatures above 150 'F. Further, these l limits are bounded by the licensee's accident and criticality analysis. SFP water i

temperature is provided locally at the discharge of the two SFP cooling pumps and locally at the outlet of the two SFP cooling heat exchangers Further, the licensee proposes that if SFP temperatures are not met, fuel assemblies and crane loads will be placed in a safe l

condition, further movement of fuel and crane loads will be suspended, and action will be taken to restore SFP water temperature, if SFP water temperature cannot be restored within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, containment integrity will be set.

DTS 3/4.1.1.c establishes SFP water chemistry limits for pH at 5.0 to 9.0 and conductivity less than or ettual to 10.0 micromhos per cm at 77 'F. These limits provide j reasonable assurance that SFP water quality will r'ot result in unacceptable degradation of t

h

. . - .. _ - _ .- ~ ,,- . _ . , _ _ - . _ - _

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~t he spent fuel and SFP liner. The licensee also proposes a SFP water chemistry program as DTS 6.6.2.9. UFHSR Chapter 9.1.3.3.3, " Spent Fuel Pool Water Chemistry,"

describes that the typical SFP water chemistry is pH - 6.9 and conductivity - 0.3 rr.icrombos, with a turbidity of 20 parts per billion (ppb). Further, the licensee proposes that for out-of-specification chemistry, corrective actions will be initicted to meet chemistry requirements within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and that SFP water will be sampled once a day until the limits are met. If water quality cannot be restored within one week, the licensee will prepare and submit a special report to the NRC within 31 days identifying causes and

! corrective actions to ensure future water quality.

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The staff finds the proposed deletion of CTS 6.7 and new DTSs 2.0. 3/4.1,1. a, b, and c, 5.2.2, and 5 '. 3 acceptable. The DTSs provide reasonable assurance that spent fuel will be stored safely, appropriate actions will be taken to mitigate and correct off-normal conditions, and periodic surveillances will be conducted to monitor SFP water chemistry.

The proposed limits are consistent with licensee analysis and provide sufficient margin between the limit and a condition resulting in unsafe spent fuel storage.

CTS 6.8, " Procedures" Consumers proposes a number of changes to CTS requirements for procedures. Although QAR requirements for procedures have been found to be acceptable (as evaluated above),

j' the following supplements the above evaluation. The licensee proposes to retitle CTS 6.8, "Proceduos," to DTS 6.6, " Procedures and Programs," thereby combining the various CTS requirements for procedures and programs into one DTS section. In particular, CTS 6.8.1 required written procedures for all SSCs and safety actions defined in the BRP QPD and required that these procedures meet or exceed the requirements of ANSI N18.7, as endorsed by CPC-2A. Consumers proposes to revise this requirement to reflect the permanently shutdown and defueled condition of the BRP facility by adding reference to " safety-related" SSCs; maintaining reference to the BRP QPD, the ANSI standard (adding the reference year of 1979) and CPC-2A; and increasing the scope of the requirement to SSCs identified as ISSSF and IMCRH. Further, the licensa proposes to add that written procedures shall be established, implemented, and maintained for the site security plan, site emergency plan, quality program description, and all programs listed in DTS 6.6.2. The staff notes that the licensee's proposed changes do not result in a net reduction in TS requirements and that the changes are consistent with other previously approved defueled TSs and 10 CFR 50.36(c)(6). Additionally, BRP proposes to increase the applicability of TS procedure requirements to SSCs that are ISSSF and IMCRH and require that written procedures be established, implemented, and maintained for the BRP Quality Program Description (CPC-2A). This increase in scope provides additional assurance that activities at the BRP facility will be conducted in accordance with reviewed and approved procedures. The staff finds these changes acceptable.

The licensee proposes to relocate CTS 6.8.2 regarding PRC procedure reviews to the

{ licensee-controlled QPD. This change is consistent with AL 95-06 and this type of detail is not required in TS based on the 10 CFR 50.36(c)(2)(ii) criteria. The staff finds this change acceptable.

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l L ' CTS, "6.9, "Ranortina Reauirements" t  ;

I The licensee proposes for deletion CTS 6.9.1, " Routine Reports," which provides information regarding where to send reports to the Commission. This information is provided in 10 CFR 50.4 and not required in TSs. The staff find this change acceptable.

CTS 6.9.1.1 through 6.9.1.3 requires that start-up reports be submitted to the i

. Commission. This' CTS is applicable during the original start-up testing program performed by Consumers during initial criticality approximately 37 years ago. This CTS

- section is not applicable during the permanently shutdown and defueled status of the BRP facility. The staff finds this change acceptable.

I CTS 6.9.1.4 and 6.9.1.5 require, in part, the licensee to submit an annual report covering occupational exposure for the previous calendar year. DTS 6.7.1, " Annual Occupational l Exposure Report," was written, in part, to replace the CTS 6.9.1.4 and 6.9.1.5 requirerr.ents, in particular, the licensee proposes to delete reference to reactor operations, refueling, inservice inspection, and 10 CFR 20.407. The staff finds the deletion of reference to reactor operations, refueling, and 10 CFR 20.407 acceptable, because these requirements are not applicable to the permanently shutdown and defueled status of the BRP facility. Further, the staff notes that occupational exposure associated i with fuel handling (although not considered " refueling" as defined by CTSs 1.2.3 and l 1.2.4) is an " operation," "special maintenance," or " waste processing" activity that  ;

requires associated dose to be submitted in accordance with the DTS 6.7.1 reporting ]

requirement; also ' included would be the CTS 6.9.1.5 requirement to report " inservice inspection" doses. Therefore,. doses from inservice inspection would also be considered an " operation" or "special maintenance" activity. Further, the deletion of the reference to l 10 CFR 20.407 is acceptable, because this reference is provided for information and does  ;

riot set forth any requirements. The staff finds the changes to CTS 6.9.1.4 and 6.9.1.5

, . and DTS 6.7,1 acceptable. {

i CTS 6.9.1.6, " Monthly Operating Rerart," requires Consumers to submit to.the .

Commission information regarding operating and shut down statistics. This information is i not necessary during the permanently shutdown and defueled condition of the BRP I facility. The staff finds this change acceptable.

Consumers proposes to delete line item: CTS 6.9.2, " Unique Reporting Requirements." '

l This is an editorial change and does not impact CTS requirements. The staff finds this l- change acceptable, i

CTS 6.9.2.1, " Annual Radiological Environmental Monitoring Report," requires, in part, the submittal of reports to the Commission " covering operation of the unit during.the previous calendar year," the land use census (CTS 13.2.3), and summaries, interpretation and statistical svaluation of the results of the radiological environmental surveillance activities, tabulated results, sampling methods and results, missed data, etc. Further, CTS 13.2.1 through 13.2.5 requires and states the specifit information obtained frnm the radiological f

, a l

environmental monitoring program to be included in this report. Lastly, CTS 6.9.2.1 requires that this report be submitted prior to May 1, of each year and provides additional administrative information. The licensee proposes to replace CTS 6.9.2.1 in its entirety with the following DTS 6.7.2 paragraph that represents editorial changes and a l consolidation of CTS 6.9.2.1 requirements:

An annual radiologicsi environmental monitoring operating report covering operation of the facility during the previous celendar year shall be submitted l

prior to May 1 of each year. The report shallinclude summaries, interpretations, and statistical evaluation of the results of the Radiological Environmental Monitoring Program for the reporting period. The material provided shall be consistent with the objectives outlined in the ODCM and Sections IV.B.2, IV.B.3 and IV.C of Appendix l to 10 CFR Part 50.

The staff finds these changes and DTS 6.7.2 acceptable, because they are consistent with the guidance in GL 89-01, " Implementation of Programmatic Controls for Radiological Effluent Technical Specifications in the Administrative Controls Section of the Technical Specifications and the Relocation of Procedural Details of RETS to the Offsite Dose Calculation Manual or to the Process Control Program," and 10 CFR 50.36(c)(6).

CTS 6.9.2.2, " Annual Radioactive Effluent Release Report," requires, in part, t.he submittal of a report " prior to May 1 of each year in accordance with 10 CFR 50.36(a)(2)... [and that thel format sad content of the report shall be in accordance with Regulatory Guide 1.21, Revision 1, dated June 1974." CTS 6.9.2.2 provides specific detail as to gaseous

effluents, liquid effluents, solid waste, radiologicalimpact on man, and the processing of l PCP (Process Contml Program) and ODCM changes. The licensee proposes to renumber CTS 6.9.2.2 as DTS 6.7.3 and relocate the preponderance of CTS 6.9.2.2 detail to licensee-controlled documents. In particular, the licensee proposes DTS 6.7.3 as

An annual radioactive affluent release report covering operation of the

facility during the previous calendar year shall be submitted prior to May 1 of each year. The report shallinclude a summary of the quantities of l radioactive liquid and gaseous effluents and solid waste released from the i facility. The material provided shall be consistent with the objectives outlined in the ODCM and the PROCESS CONTROL PROGRAM, and shall

! comply with the requirements of 10 CFR 50.36a and Section IV.B.1 of Appendix I to 10 CFR Part 50.

The staff finds these changes and DTS 6.7.3 acceptable, because they are consistent with the guidance in GL 89-01 and 10 CFR 50.36(c)(6).

CTS 6.9.3, "Special Reports," requires that reports be submitted to the Commission for inservice inspection, fire system, high-range containment gamma monitoring systems, and stack gas monitoring system. Further, CTS 6.9.3 states where these reports are required to be sent. The licensee proposes that CTS 6.9.3 be renumbered to DTS 6.7.4 l

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I and proposes: (1) editorial changes; (2) new DTS 6.7.4.a that requires a report should ,

SFP water quality limits of DTS 3/4.1.1.c be exceeded and not recovered af ter one week: '

(3) DTS 6.7.4.b that requires a report if sealed source contamination limits of DTS 3/4.4.1 are exceeded (CTS 6.16.3 of CTS Section 10); (4) DTS 6.7.4.c that requires a I report for inservice inspection results required by 10 CFR 50.55a and Section XI of the ASME Boiler and Pressure Vessel Code (CTS 6.9.3.a); (5) removal of fire system reports i (CTS 6.9.3.b); (6) deletion of high-range containment gamma monitoring system reports I (CTS 6.9.3.c): and, (7) removal of stack gas monitoring system reports (CTS 6.9.3.d).

The licensee states in its letter dated July 21,1998, that fire system reports are not required in the permanently shutdown and defueled status as described in 10 CFR 50.48(f) and the staff notes that fire system reporting requirements are described in l UFHSR Chapters 9.5.1.1 (CTS 3.3.3.8.b, Action b), 9.5.1.2.1 (CTS 3.7.11.1, Action c.2), and 9.5.1.2.4 (CTS 3.7.11.2, Action a and b); high-range gamma monitoring l system reports are not required because these monitors were used for operating reactor accidents and that these types of accidents are not applicable to a permanently shutdown and defueled reactor; and, stack gas monitoring system repart associated with gaseous effluent instrumentation will be relocated to paragraph 1.1.2 of Section I of the ODCM.

The staff finds the deletion / relocation of CTSs 6.9.3 and 6.16.3 and DTS 6.7.4 acceptable as described, because there is no net reduction in reporting requirements or safety.

CT S 6.10, " Record Retention," provides detailed information as to the type of records that are required for retention and duration of retention. As evaluated earlier in this Safety Evaluation, the licensee proposes relocation of CTS 6.10 to licensee-controlled documents, namely CPC-2A, and the renumbering of CTS 6.10 to DTS 6.8. The staff finds these changes acceptable.

The licensee proposes new TS requirement DTS 6.9, " Reportable Events," as "any event or condition that must be reported to the NRC in accordance with 10 CFR 50.72,10 CFR 50.73, or 10 CFR 50.9(b)." The NRC finds DTS 6.9 a :ceptable.

The licensee proposes to place CTS programs under a common DTS paragraph, numbered and titled as DTS 6.6.2, " Programs,' as previously described. In particular, CTS 6.11,

" Radiation Protection Program," was renumbered to DTS 6.6.2.1; CTS 6.12, "High Radiation Area," was renumbered to DTS 6.6.2.2; CTS 6.13, " Environmental Qualification," was deleted by previous license amendment; CTS 6.14, " Process Control Program," was renumbered to DTS 6.6.2.3; and, CTS 6.15, "Offsite Dose Calculation Manual," was renumber to DTS 6.6.2.4. The licensee also proposes to clarify that four CTS subsections and associated requirements will now be considered programs, namely:

(1) CTS 13.1, " Radiological Effluent Releases," as DTS 6.6.2.5, " Radioactive Effluent Controls Program;" (2) CTS 13.2, " Radiological Environmental Monitoring," as i DTS 6.6.2.6, " Radiological Environmental Monitoring Program;" (3) CTS pages 116 through 127 as DTS 6.6.2.7, " Fire Protection Program;" and, (4) CTS 9.0, " Inservice

l. Inspection and Testing," as DTS 6.6.2.10. Consumers also proposes two new programs:

DTS 6.6.2.8, " Cold Weather Protection Program," and DTS 6.6.2.9, " Spent Fuel Pool

Water Chemistry Program." Further, the description under CTS 6.11, " Radiation Protection Program," was relocated in its entirety to DTS 6.6.2. The licensee also proposes to relocate Nuclear Operations Department review and approval requirements of CTSs 6.14.1.c and 6.15.1.c into the OPD. DTS 6.14.1.b and 6.15.1.b requirements were relocated to the DTS with only editorial changes. The staff finds these changes j acceptable, because they clarify TS requirements, are considered editorial changes that l improve the TSs, and are consistent with the guidance in AL 95-06. Additional staff i

evaluation of the proposed SFP water chemistry and cold weather protection programs is provided later in this Safety Evaluation.

l CTS 6.12, "High Radiation Area"

- The requirements of CTS 6.12.1 were relocated in their entirety to DTS 6.6.2.2.1 with the following exceptions. The licensee proposes to: (1) title this DTS as " Dose Rates less

- than or equal to 1000 Millirem per Hour;" (2) add the phrase " greater than 100 mrem /hr but" prior to the first use of the phrase "less than" in the first paragraph; (3) add the phrase "or equal to" prior to both uses of the phrase "1000 mrem /hr" so that the requirement for exemption from working under a radiation work permit (RWP) includes dose rates less than or equal to 1000 mrem /hr; (4) replace the CTS 6.12.1.c phrase "e.g.,

Health Physics Technician" with "e.g., Radiation Protection Technician;" and, (5) delete the CTS 6.12.1.c phrase "and shall perform periodic radiation surveillance as specified by the Chemistry and Radiation Protection Supervisor in the RWP." The proposed changes above clarify the requirements of the TSs and are consistent with 10 CFR 20.1003, or are i not required to be included in the TSs. Also, as described in its letter dated December 21, 1998, Consumers initially proposed that the portion of DTS 6.6.2.2.1.b regarding the radiation monitoring device be deleted; however, the licensee then withdrew this request

- and maintained the CTS requirement. The staff finds these changes acceptable.

l The requirements of CTS 6.12.2 were relocated to DTS 6.6.2.2.2 in their entirety with .

the following exceptions. The licensee proposes to (1) title this DTS as " Dose Rates greater than 1000 Millirem per Hour" and (2) replace "the administrative control of the Shift Supervisor on duty and/or health physics supervision" with " administrative controls specified in the facility administrative procedures." The poposed changes above clarify

l. the requirements of the TSs and are consistent with 10 CFR 20.1003, or are not required L to be included in the TSs. Also, as described in its letter dated December 21,1998, l- Consumers initially proposed that: (1) DTS 6.6.2.2.2 be applicable to dose rates equal to i 1000 mrem /hr; however, the licensee withdrew this request, because this proposed change was inconsistent with the DTS 6.6.2.2.1 and (2) CTS 6.12.2, regarding RWP will specify the dose rate levels in the immediate work area and the maximum stay time for

! individuals in that area, be replaced with a requirement that radiation conditions be communicated to the individuals; however, the licensee withdrew this request and

, . maintained the CTS 6.12.2 requirement. The staff finds these changes acceptable.

The licensee proposes to delete CTS 6.13, " Environmental Qualification," in its entirety, j This CTS has no requirements associated with it and, in accordance with 10 CFR 50.49, a E

,, + -n + - -n,-.e --- -

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50-plant that has submitted certifications required under 10 CFR 50.82(a)(1) need not establish a program for qualifying electrical equipment. The staff finds this change acceptable.

CTS 6.14, " Process Control Program," requires, in part, that changes to the program be submitted to the Commission and that this submittal contain sufficient detail, a determination that the change did not reduce the overall conformance of the product to existing criteria, and documentation that the changes had been reviewed by the responsible Nuclear Operations Department (NOD) per CPC-2A. The licensee proposes to renumber this CTS as DTS 6.6.2.3, make editorial changes, and maintain all requirements except relocating the CTS 6.14.1.c requirement of the NOD review to the licensee-controlled OPD. The staff notes that the proposed changes do not result in a net reduction in requirements and are consistent with 10 CFR 50.36(c)(6). Further, the relocation of NOD review is consistent with the AL 95-06. Based on this Safety Evaluation, the staff finds these changes acceptable.

CTS 6.15, "Offsite Dose Calculation Manual (ODCM)," requires, in part, that changes to the program be submitted to the Commission and that this submittal contain sufficient detail, a determination that the change did not reduce the accuracy or reliability of the dose calculations or setpoint determinations, and documentation that the change was reviewed and approved by NOD per CPC-2A. The licensee proposes to renumber this CTS as DTS 6.6.2.4, make editorial changes, and maintain all requirements except relocating the CTS 6.15.1.c requirement of the NOD review to the BRP QPD. The staff notes that the proposed changes du not result in a net reduction in requirements and are consistent with 10 CFR 50.36(c)(6). Further, the relocation of NOD review is consistent with the AL 95-06. Based on discussion in this Safety Evaluation, the staff finds these changes acceptable.

CTS 6.16, " Radioactive Materials Sources," requires, in part, (a) testing for leakage and contamination at intervals not to exceed six m$ths (CTS 6.16.1.a); sets forth exempt quantities (CTS 6.16.1.b); and provides allowance for sealed sources that are stored and not being used (CTS 6.16.1.c); (b) test criteria (CTS 6.16.2); (c) reportability requirements if testing identifies the presence of material in excess of limits (CTS 6.16.3);

and (d) qualification requirements for personnel performing the tests (CTS 6.16.4).

Consumers proposes to make editorial changes to this CTS and to relocate these requirements in its entirety to DTS 3/4.4, " Sealed Source Contamination," with the following exceptions. CTS 6.16.1.a states that "any licensed sealed source is exempt from such leak tests when the source contains 100 microcuries or less of beta and/or gamma emitting material or 10 microcuries or iets of alpha emitting material." Consumere proposes to change this requirement into an LCO-type format and to lower the alpha contamination limit to "5 microcuries or more." The staff finds these changes and DTS j- 3/4.4.1 acceptable, because the proposed changes do not result in a not reduction of TS requirements or safety.

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CTS SECTION 11 (no title)

CTS 11.3/4.1.4, " Emergency Coro Cooling System;" Table 11.3/t ' 4a, " Instrumentation

} That initiates Core Spray;" Table 11.3.1.4b, " Fire Pump Acceptance Criteria," CTS l

11.3/4.1.5 regarding the reactor depressurization system (RDS);" Table 11.3.1.5,

" Instrumentation That initiates RDS Operation;" CTS 11.3/4.3.4, " Containment Spray System;" and, Table 11.4.3.4, " Instrumentation That initiates Enclosure Spray," are l

' LCOs, surveillance requirements, and operability conditions associated with safety-related systems necessary for the safe operation or post-accident mitigation of the BRP power  !

reactor. In particular, the core spray cools the reactor fuelin the event of a loss of coolant accident, the RDS depressurizes the primary system so that a low pressure water

! source can inject water into the reactor vessel during a small to intermediate size loss of coolant accident, and the containment spray system reduces containment pressure and l

temperature in the event of a loss of coolant accident. Therefore, these systems are j required to be operable during reactor operation and the associated CTS operability l requirements and information contained in these requirements are also associated with l reactor operation. The licensee proposes to delete these CTS sections in their entirety.

j Since the BRP facility is permanently shut down and defueled, these systems are no l

longer necessary nor required to assure public health and safety. The staff finds these changes acceptable.

The requirements and operability information in CTSs 11.3/4.5.3 entitled "Em rgency Power Sources" are "to assure the capability of the emergency power sources to provide l power required for emergency equipment in the event of a Loss of Coolant Accident."

l These requirements are provided for "all reactor operating conditions except cold i

shutdown." Regarding CTS 11.3/4.5.3 reference to " refueling," CTS 1.2.3 defines a l refueling operation as "any operation with any of the reactor vessel closures open during

! which a core alteration, or other operation which might increase core reactivity, is in progress" and CTS 1.2.2 defines a core alteration as "any completed planned sequence of movements of core components resulting in either a net change in the configuration of the reactor core or a net gain in core reactivity." The licensee proposes to delete CTS 11.3/4.5.3 in its entirety. Since the BRP reactor is permanently shut down and defueled, these requirements are no longer applicable or necessary to assure public health

. and safety. Nonetheless, the licensee proposes DTS 3/4.1.2, which requires various l combinations of SFP make-up water sources and electrical power supplies, to provide l assurance that SFP refill capability exists. The staff finds these changes acceptable.

CTS SECTION 12, FIRE PROTECTION PROGRAM The licensee proposes to relocate the following CTS fire protection requirements to licensee-controlled documents: CTS 3/4.3.3.8, " Fire Detection;" Table 3.3-8, " Fire

! Detection Instruments;" CTS 3/4.7.11.1, " Fire Suppression Water System;"

CTS 3/4.7.11.2, Fire Spray and/or Sprinkler Systems; CTS 3/4.7.11.5, " Fire Hose

! Stations;" and, CTS 3/4.7,12. " Penetration Fire Barriers." The licensee also proposes to

] delete CTS 3/4.7.13. " Alternate Shutdown System;" Table 3.3-9, " Alternate Shutdown 5

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System Equipment;" and, Table 4.3-9, " Alternate Shutdown System Instrument i Surveillance Requirements," in its entirety. The staff notes that CTSs 3/4.7.11.3. and 4 are not listed in the CTS and do not have any requirements.

As described in the CTS: (1) fire detection instrumentation is required to be operable when the equipment in the area is required to be operable; this instrumentation " ensures that adequate warning capability is available for the prompt detection of fires. This capability is required in order to detect and locate fires in its early stages. Prompt detection of fires will reduce the potential for damage to safety related equipment and is an integral element in the overall facility fire protection program." (2) Fire suppression systems are required to be operable at all times; this system " ensures that adequate fire suppression capability is available to confine and extinguish fires occurring in any portion of the facility where safety related equipment is located... The collective capability of the fire suppression system is adequate to minimize potential damage to safety [-]related equipment and is a major element in the facility fire protection program." (3) The fire spray /or sprinkler systems and fire hose stations shall be operable at all times when the equipment in the area is required. (4) Penetration fire barriers are required to be operable at all times; this system " ensures that fires will be confined or adequately retarded from spreading to adjacent portions of the facility. This design fe .ure minimizes the possibility l of a single fire rapidly involving several areas of the facility prior to detection and extinguishment. The penetration fire barriers include active and passive elements in the facility fire protection program and are subject to periodic inspection." (5) The alternate shutdown system shall be operable during reactor power operation; this system provides assurance that safe reactor shutdown and cooldown can be achieved in the event of a major fire in critical areas of the plant in accordance with Appendix R to 10 CFR Part 50.

As previously evaluated in this Safety Evaluation, GL 86-10, " Implementation of Fire Protection Requirements," and GL 88-12," Removal of Fire Protection requirements from Technical Specifications," provides guidance on the relocation of TS fire protection requirements to licensee-controlled documents. In its July 21,1998, letter to the staff, Consumers stated that fire protection requirements had been previously added to the UFHSR in anticipation of their removal from the CTS; however, the removal of these requirements from the CTS was never accomplished. Consumers also stated that "[p]rior to Revision 7 of the UFHSR, there was a one-to-one correspondence between the Technical Specifications and the UFHSR, confirming that the facility's fire protection requirements resided in the appropriate plant documents." However, Consumers has subsequently deleted the UFHSR fire protection operating requirements associated with l the emergency core cooling system (ECCS) and the alternate shutdown system (ASS) because these systems are no longer required to be operable because the facility is-j permanently shut down and defueled. In addition, the licensee stated its intention that selected fire protection equipment will be removed during decommissioning when those systems and areas are no longer required to be protected.

As provided in GL 88-12, the staff does not intend to repeat its review of the BRP Fire Protection Program incorporated in the UFHSR. The relocation of CTS fire protection l

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requirements to licensee-controlled documents is acceptable based on the licensee's statements provided above. The deletion of UFHSR fire protection requirements for ECCS and ASS and the inapplicability of Appendix R requirements are acceptable based on the permanently shutdown and defueled condition of the BRP facility. Further, the licensee proposes DTS 6.6.2.7 to require "A fire protection program meeting the requirements of 10 CFR 50.48(f) shall be established, implemented, and maintained." 10 CFR 50.48(f) requires that this program shall (i) reasonably prevent such fires from occurring, (ii) rapidly detect, control, and extinguish those fires that do occur and which could result in radiological hazards, and (iii) ensure that the risk of fire-induced radiological hazards to the public, environment, and plant personnelis minimized. Therefore, the bases for the BRP fire protection CTSs are equivalent to the fire protection regulations applicable to a

, permanently shutdown and defueled facility such as BRP. Lastly,10 CFR 50.48(f) l requires licensees to assess their programs on a regular basis and states that "the licensee l may make changes to the program without NRC approvalif these changes do not reduce l

the effectiveness of fire protection for facilities, systems, and equipment which could result in a radiological hazard, taking into account the decommissioning plant conditions and activities." Therefore, there is reasonable assurance that adequate protective and mitigative fire protective actions can and will be implemented by the licensee to provide assurance that decommissioning activities will not be inimical to public health and safety.

The staff finds the relocation of CTS fire protection requirements and changes described above acceptable.

CTS SECTION 13, RADIOLOGICAL EFFLUENT TECHNICAL SPECIFICATIONS (RETS)

Radioloaical Effluent Controls Proaram (RECP) and Radioloaical Environmental Monitorina Proaram (REMP)

The NRC staff has examined the contents of the RETS and has determined that programmatic controls can be implemented in the Administrative Controls section of the TSs to satisfy existing regulatory requirements for RETS. Further, the procedural details of the CTS on radiological effluents and radiological environmental monitoring can be relocated to the ODCM and solid radioactive waste can be relocated to the Process Control Program. These actions simplify the RETS, meet regulatory requirements for radiological effluents and radiological environmental monitoring and are provided as a line-item improvement of the CTSs. The RETS remaining conform to the regulatory requirements of 10 CFR 20.1301,10 CFR 20.1302,40 CFR Part 190,10 CFR 50.36a, and Appendix 1 to 10 CFR Part 50. The procedural details included in the licensee's CTS on radiological effluents, solid radioactive wastes, environmental monitoring, and associated reporting requirements will be relocated to the ODCM or PCP, as appropriate.

The licensee will handle future changes to these procedural details in the ODCM and PCP i under the TS Administrative Controls section and applicable regulatory requirements.

Further, the definitions for ODCM and PCP were updated to reflect these changes, as previously described in this Safety Evaluatior..

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GL 89-01 and NUREG-1302, "Offsite Dose Calculation Manual Guidance: Standard Radiological Effluent Controls for Boiling Water Reactors," provides guidance as to how a licensee relocates RETS to licensee-controlled documents. The GL provides model specifications, guidance for the relocation of RETS, and encourages licensees to propose changes that are consistent with the GL guidance. However, this GL was written for power reactor facilities licensed to operate. Because the BRP facility is permanently shut down, defueled, and precluded by regulation from reactor power operation, sections of GL 89-01 are no longer applicable. Further, the staff does not intend to repeat technical reviews of the relocated procedural details because their consistency with the applicable regulatory requirements is a matter of record from past NRC reviews of RETS. If licensees make other than editorial changes in the procedural details being transferred, these changes should be identified by the licensee.

The licensee's CTS amendment request dated September 19,1997, included its proposed DTS and ODCM to reflect the permanently shutdown and defueled status of the BRP facility. However, the ODCM, Revision 0, did not identify proposed changes nor did it provide confirmation that the CTS RETS requirements were relocated to the licensee-controlled ODCM consistent with the guidance provided in GL 89-01.

The NRC staff informed Consumers by letter dated October 14,1997, that the staff was not required to review or approve changes to the ODCM. Further, by letter dated April 16,1998, the staff requested Consumers to provide (1) confirmation that the details covered in the current BRP RETS, consisting of LCOs, their applicability, remedial actions, surveillance requirement, and Bases were relocated to the ODCM, PCP, RECP, and REMP as appropriate and in a manner that ensures that these details will be incorporated in applicable prucedures, (2) a summary listing of each change other than editorial change made during the transfer of details from the CTS to applicable procedures and programs, and (3) an explanation why the change or deletion was made. This request was made consistent with the guidance provided in GL 89-01. Consumers responded by letter dated July 21,1998, that "[alssurance that the ODCM will contain the necessary requirements and be implemented by facility procedures is provided by (DTS) 6.6.2.5 and 6.6.2.6." Consumers also provided a specification-by-specification summary of each change, other than editorial, and its basis made during the transfer of RETS from the CTS to its licensee-controlled ODCM.

The staff used the information provided in the July 21,1998, letter in understanding the licensee's proposed relocations of RETS requirements. The licensee also included draft information in its July 21,1998, letter; however, this information was not part of the staff's basis for approval of the DTS. Further, although the licensee stated its intention to implement the ODCM (with proposed changes as provided in its July 21,1998 letter) coincident with implementation of the DTS, approval of the DTS does not represent approval of proposed program changes once located in licensee-controlbd documents.

These documents, such as the ODCM and PCP, are subject to NRC inspection and enforcement.

The licensee proposes to relocate the preponderance of requirements in CTS 13.1,

" Radiological Effluent Releases;" Table 13-1, " Radiological Effluent Monitoring Instrumentation;" Table 13-2, " Radiological Effluent Monitoring Instrumentation Surveillance Requirements;" CTS 13.1.2, " Liquid Effluents Concentration;" CTS 13.1.3,

" Gaseous Effluents Dose Rate," Table 13-3, " Radioactive Waste Sampling and Analysis Program;" CTS 13.1.4, " Effluent Dose;" CTS 13.1.5, " Solid Radioactive Waste;"

CTS 13.1.6, " Total Dose;" CTS 13.2, " Radiological Environmental Monitoring;"

Table 13.3-1, " Radiological Environmental Monitoring Program;" Table 13.3-2,

" Reporting Levels for Radioactivity Concentrations in Environmental Samples;" and, Table 13.3-3, " Detection Capabilities for Environmental Sample Analysis" to the licensee-controlled ODCM, REMP, or PCP.. Regarding CTS requirements that the licensee proposes to retain in the DTS, Consumers made editorial and administrative changes to improve the standardization of its TSs and other changes based on the permanently shut down and defueled status of the BRP facility. These changes are described below.

DTS 6.6.2.5, " Radioactive Effluent Controls Program," defines the RECP as a " program, conforming with 10 CFR 50.36a, for the control of radioactive effluents and for maintaining doses from radioactive effluents to members of the public as low as reasonably achievable. The program (1) will be contained in the ODCM, (2) will be implemented by facility procedures, and (3) will include remedial actions to be taken whenever program limits are exceeded." The staff finds the introductory paragraph of DTS 6.6.2.5 acceptable.

The licensee proposes to consolidate CTS RECP requirements under DTS 6.6.2.5 as individual requirements, consistent with the guidance provided in GL 89-01, specifically:

Radioactive liquid and gaseous monitoring instrumentation requirements of CTS 13.1.1.1; CTS 13.1.1.2: Table 13-1; Table 13-2: CTS 13.1.2.2; Table 13.3-1; and, Table 13.3-3 were either (1) relocated, in part, to the licensee-controlled ODCM, (2) deleted, due to their inapplicability to the permanently shutdown and defueled condition of the BRP

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facility and/or (3) revised or edited to improve format. Further, Consumers proposes DTS 6.6.2.5.a conceming "[Ilimitation on the operability of radioactive liquid and gaseous monitoring instrumentation including surveillance tests and setpoint determination in accordance with the methodology in the ODCM" as a replacement for DTS 13.1.1.1. The licensee also informed the staff that the following monitors will be deleted from the RETS:

air ejector offgas monitor, because this system is not necessary for a plant that is permanently shut down and defueled; iodine sampler, because more than 10 half lives of decay have occurred from the iodines; and, high-range noble gas monitor, because the remaining noble gases are not sufficient to activate the gamma-sensitive high-range monitor. The use of a normal-range monitor sensitive to beta radiation will be used to monitor krypton-85. The licensee also plans to: (1) replace reactor coolant grab samples with reactor and turbine building air samples; (2) modify the sampling requirements fer the

" circulating water discharge monitor;" and, (3) change surveillance frequency from every

" refueling" to " annual." The staff notes that: (a) the proposed relocation of RETS requirements and DTS 6.6.2.5.a are consistent with the guidance in GL 89-01 and (2)

the removal of the radiation monitors, the change to reactor building and turbine building grab samples, the change in surveillance frequency from every refueling cycle to annual, and modification of the sampling requirements for the circulating water discharge monitors are consistent with the permanently shutdown and defueled condition of the plant. The staff finds the relocation of these CTS RETSs, DTS 6.6.2.5.a, and the above proposed changes acceptable.

The licensee proposes to renumber CTS 13.1.2.1 as DTS 6.6.2.5.b and editorially revise CTS 13.1.2.1 to require "[llimitations conforming to 10 times the concentration values specified in Appendix B, Table 2, Column 2 to 10 CFR 20.1001 - 20.2402 for radioactive material released in liquid effluents to unrestricted areas." Consumers also proposes deletion of the CTS 13.1.2.1 requirement pertaining to dissolved or entrained noble gases.

The staff notes that the requirement to limit dissolved and entrained noble gases to 2 x 10-' microcurie per milliliter is no longer applicable. This change is consistent with the guidance in GL 89-01 and the renumbering of CTS 13.1.2.1 to DTS 6.6.2.5.b (with editorial changes) is administrative. The staff finds these changes acceptable.

The licensee proposes CTSs 13.1.2.2 and 3 (regarding liquid effluents) and CTSs 13.1.3.2 and 3 (regarding gaseous effluents) as DTS 6.6.2.5.c requiring the

'"[mlonitoring, sampling, and analysis of radioactive liquid and gaseous effluents in accordance with 10 CFR 30.1302 and with the methodology and parameters in the ODCM." Other information applicable to these requirements was relocated to the licensee-controlled ODCM. The staff notes that these proposed changes are consistent with the guidance in GL 89-01 and the relocated CTS information is not required to be included in TSs based on 10 CFR 50.36(c)(6) and GL 89-01. The staff finds these changes acceptable.

The licensee proposes to relocate CTS 13.1.3.1 as DTS 6.6.2.5.g concerning dose rate limits due to radioactive materials released in gaseous effluents. The licensee also proposes to (1) replace " Figure 2.1" with " Figure 5.1-1" to correspond with the numbering in the DTS and (2) to delete the iodine dose rate limits. Also, as described in its letter dated December 21,1998, Consumers initially proposed that the requirements of CTS 13.1.3.1 be replaced in its entirety with a requirement that "[l] imitations conforming to 10 times the concentration values specified in Appendix B, Table 2, Column 1 to 10 CFR 20.1001-20.2402, averaged for one hour from radioactive material released in gaseous effluents to areas beyond the site boundary;" however, the licensee then withdraw this request and maintained the CTS 13.1.3.1 requirement. As previously described in this Safety Evaluation, the deletion of TS requirements pertaining to iodines and the proposed change to Figure 2.1 are acccptable. The staff finds DTS 6.6.2.5.g and associated changes acceptable, because the changes are editorial and equivalent dose rate

limits are maintained.

l The licensee proposes to relocate CTS Table 13-3 radioactive waste sampling and analysis information to the ODCM. The staff finds the relocation of this information

acceptable, because this change is consistent with the guidance in GL 89-01.

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o u The licensee proposes to replace and modify CTS 13.1.4.1 as DTS 6.6.2.5.d concerning "ll] imitations conforming to Appendix l to 10 CFR Part 50 on the annual and quarterly doses or dose commitment to a member of the public from radioactive materials in liquid effluents released from the facility to unrestricted areas." The staff finds this change ano DTS 6.6.2.5 d acceptable, because these changes maintain equivalent liquid dose requirements and the proposed change is consistent with the guidance in GL 89-01.

The licensee proposes to replace and modify CTS 13.1.4.2 as DTS 6.6.2.5.h concerning

"[l] imitations conforming to Appendix ! to 10 CFR Part 50 on the annual and quarterly air doses resulting from noble gases released in gaseous effluents from the facility to areas beyond the Site Boundary." The staff finds this change and DTS 6.6.2.5.h acceptable, because there changes maintain equivalent air dose requirements and are consistent with the guidance in GL 89-01.

The licensee proposes to relocate CTS 13.1.4.3 to DTS 6.6.2.5.j concerning doses to members of the public from iodines, tritium, and radionuclides in particulate form with half lives greater than 8 days in gaseous effluents released to areas at or beyond the site boundary. The licensee also proposes to delete reference to iodines and to change

" Figure 2.1" to " Figure 5.1-1." The staff notes that as described in its letter dated December 21,1998, Consumers initially proposed that the requirements of CTS 13.1.4.3 be deleted in its entirety;" however, the licensee then withdrew this request and a

maintained the CTS 13.1.4.1 requirement as DTS 6.6.2.5.] as indicated above. The staff finds the deletion of CTS requirements for iodines acceptable (as evaluated above).

Further, the figure change and relocation of the TS requirement are acceptable, because these changes are editorial and an equivalent dose limit requirement is maintained.

The licensee proposes DTS 6.6.2.5.f to ensure that the radioactive waste treatment systems are utilized when releases could exceed two percent of the guidelines set in Appendix l of 10 CFR Part 50. The staff finds the following DTS 6.6.2.5.f acceptable, because the change is consistent with the guidance in GL 89-01.

Limitations of the operability and use of the liquid and gaseous effluent treatment systems to ensure that the appropriate portions of these systems are used to reduce releases of radioactivity when the projected doses in a 31-day period would exceed 2 percent of the guidelines for the annual dose or dose commitment conforming to Appendix 1 to 10 CFR Part 50.

The licensee proposes to revise CTSs 13.1.4.4 (regarding radioactive materials) and 13.1.6.2 (regarding liquid and gaseous effluents) as DTS 6.6.2.5.e concerning

"[dletermination of cumulative and projected dose contributions from radioactive effluents for the current calendar quarter and current calendar year in accordance with the methodology and parameters in the ODCM at least every 31 days." The staff finds these changes acceptable, because they are consistent with the guidance in GL 89-01.

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The licensee proposes to relocate CTS 13.1.5.1, regarding the solid radioactive waste l

system, to its PCP. Further, Consumers proposes the PCP as a program under )

DTS 6.6.2.3 and defines the PCP in DTS 1.13. The staff finds these changes acceptable, because they are consistent with the guidance in GL 89-01.

l The licensee proposes to (1) revise CTS 13.1.6 as DTS 6.6.2.5 i concerning "[Ilimitations  ;

conforming to 40 CFR Part 190 on the annual dose or dose commitment to any member of the public due to releases of radioactivity and to radiation from uranium fuel cycle 1 sources" and (2) relocate CTS 13.1.6 methodologies and evaluations to the licensee-controlled ODCM. The staff finds these changes acceptable, because they are consistent with the guidance in GL 89-01. '

The licensee proposes to relocate CTS 13.1.6.3, regarding cumulative dose contributions l from direct radiation from the reactor units and from radwaste storage tanks, to the l

licensee-controlled ODCM. In addition, this specific requirement is covered by DTS l 6.6.2.5.i concerning dose limitations conforming to 40 CFR Part 190 due to the release of radioactivity and to radiation from uranium fuel cycle sources. The staff finds the relocation of CTS 13.1.6.3 acceptable, because the change is consistent with the guidance in GL 89-01.

The licensee proposes to consolidate CTS REMP requirements under DTS 6.6.2.6 as individual requirements, consistent with the guidance provided in GL 89-01. Specifically:

the licensee proposes an introductory paragraph for DTS 6.6.2.6 that states, in part, that a program shall be provided to monitor the radiation and radionuclides in the environs of the facility. This program shall provide (1) representative measurements of radioactivity in the highest potential exposure pathways, (2) verification of the accuracy of the effluent monitoring program, and (3) modeling of environmental exposure pathways. The program shall be contained in the ODCM and conform to the guidance of Appendix I to 10 CFR Part 50. The staff finds the licensee-proposed changes and the introductory paragraph acceptable, because they are consistent with the guidance in GL 89-01 and 10 CFR 50.36(c)(6).

The licensee proposes to relocate the preponderance of requirements in CTSs 13.2.1, 13.2.2,13.2.3,13,2,4,13.2.5, Table 13.3-1, Table 13.2-2, and Table 13-3.3 to its ODCM. However, Consumers also proposes that: (1) DTS 6.6.2.6.a, to maintain assurance that monitoring, sampling, analysis, and reporting of radiation and radionuclides l

in the environment in accordance with the methodologies and parameters in the ODCM, replace CTS 13.2.1, Table 13.3-1, Table 13.3-2, CTS 13.2.2, and Table 13.3-3: (2)

DTS 6.6.2.6.b, to maintain a requirement for a Land Use Census, replace CTS 13.2.3; and, (3) DTS 6.6.2.6.c, to assure participation in sn interlaboratory program. replace

CTS 13.2.4 and 13.2.5. The staff finds DTS 6.6.2.6 and changes acceptable.

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The licensee proposes two new programs DTS 6.6.2.8, " Cold Weather Protection Program," and DTS 6.6.2.0, " Spent Fuel Pool Water Chemistry Program." As proposed,  !

the cold weather protection program "provides administrative controls to ensure that appropriate measures are implemented and maintained during cold weather to protect the facility against cold temperatures which could impact the safe storage of irradiated fuel or result in unplanned or unmonitored radioactive material release." The SFP program "uses procedures to provide controls for monitoring Spent Fuel Pool water chemistry." Used in conjunction with DTS 3.1.1, these requirements provide sufficient assurance that the SFP water environment will not result in or contribute to unacceptable structural damage of the spent fuel pool liner, fuel clad, and fuel assembly tacks. The staff notes that during reactor plant operation, Consumers implemented a cold weather protection program and maintained a SFP water chemistry program, however, these programs were not in the CTS. Therefore, the licensee's proposal to include these programs in its DTS represents additional assurance that environmental conditions and SFP water chemistry will not result in adverse plant conditions. The staff finds DTS 6.6.2.8 and 6.6.2.9 acceptable.

Staff evaluation of DTS 6.6.2.10 " Inservice inspection and Testing Program," was provided earlier in this Safety Evaluation. The staff found DTS 6.6.2.10 acceptable.

4.3 Summarv of Editorial Chanaes to Prooosed DTS This section summarizes the editorial changes made to enhance the clarity of the TSs. On September 10 and 11, and November 19.1998, these changes were discussed with the licensee. In its letter dated November 25,1989, Consumers agreed to the following changes. These changes do not represent a denial, withdrawal, or change of any licensee-proposed amendment.

(1) Table of Contents page numbering, indenting, general editing deleted the two " License" line entries

" Direct Paths" changed to " Direct Path" added the "SFP Water Chemistry Program" added the " Inservice Inspection and Testing Program" (2) DTS 1.11 hyphen removed from the word "offsite" (3) DTS 1.15, last sentence " surveillance requirement" changed to " Surveillance Requirement" (4) DTS 3.1.1.c "77 degrees F" changed to "77 *F" (5) DTS 3.1.1.d inserted spaces to "10 CFR 70.24(a)(2)"

l (6) DTS 3.1.2.a connected the word "on site" as used three times removed the hyphen from the word "offsite" (7) DTS 3.1.2, Action " specifications" changed to " Specifications" (8) DTS 3.1.3, Action changed "3.1.3.1, 3.1.3.b, or 3.1.3.c" to "3.1.3.a and 3.1.3.b" to correspond with item (8) above and replaced " specifications" with " Specifications" (9) DTS 3/4.2.1 replaced " specification" with " Specification" four times

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l l (10) DTS 3.3.1, Action replaced " specifications" with " Specifications" (11) DTS 5.1.1 replaced " Reference" with " reference"

! (12) DTS 6.2.1 replaced "on-site" with "onsite" twice l . (13) DTS 6.2.2.d hyphenated " safety (-]related functions" (14) DTS 6.2.2.d added the initialization "(ISSSF)" after the phrase

" spent fuel" and "(IMCRH)" after the phrase

" radiological hazards."

(15) Table 6.2-1 edited Table 6.2-1 line shading l (16) DTS 6.3 removed the comma from " September,1997" l (17) DTS 6.5.1 hyphens removed from "onsite" and "offsite" (18) Footnote 1, pg 6-4 placed the comma within the quotes of " equivalent" and deleted the comma after the word " engineering" (19) DTS 6.6.1.1.b and c deleted the word "and," and renumbered DTS 6.6.1.1.c to DTS 6.6.1.1.d (20) DTS 6.6.2 " specification" to " Specification" (21) DTS 6.6.2.10.c.1 "Section 50.55a(g)(6)(l)" to "Section 50.55a(g)(6)(i)"

"of sections 11.4.1.4" to "of Sections 11.4.1.4" l (22) DTS 6.6.2.5.b " Table ll" changed to " Table 2" l

(23) DTS 6.7.4.b " specification" changed to " Specification" (24) DTS 6.7.4.c "10 CFR 50.55(a)" changed to "10 CFR 50.55a" l (25) DTS 6.7.4.c changed the word " Code" to "ASME Boiler and Pressure Vessel Code" (26) DTS 6.9 inserted spaces to "10 CFR 50.72,10 CFR 50.73, or 10 CFR 50.9(b)"

5.0 STATE CONSULTATION

in accordance with the Commission's regulations, the State of Michigan official, Mr. David W. Minnaar, Chief, Radiological Protection Section, Drinking Water and Radiological Protection Division, Michigan Department of Environmental Quality, was notified on September 10,1998, of the proposed issuance of the amendment. The State official had comments regarding whether this amendment to the BRP license would result in changes to the licensee's ability to provide offsite radiological effluent monitoring and dose assessment.

On November 30,1998, the staff acknowledged the State's comments and stated that the proposed amendment of the DPR-6 license (1) removes requirements that are no longer applicable to the BRP facility because the plant is permanently shut down and defueledi(2) relocates requirements to licensee controlled-documents in accordance with

, the Commission's Policy Statement and applicable NRC guidance, (3) maintains l

requirements that remain applicable regardless of the status of the reactor plant or spent fuel storage, (4) adds new requirements that contribute to the assurance of maintaining public health and safety, and (5) revises and edits requirements to better parallel the format and content of STS and TS that have been previously approved at other power i

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reactor facilities that have permanently ceased operation and removed fuel from the reactor. The staff also informed the State representative that the licensee may make changes to its applicable programs and procedures (i.e, ODCM, REMP, and PCP) following Commission approval of the DTS but that the changes must be made in accordance with the BRP DPR-6 license and Appendix A, "Defueled Technical Specifications," to the

! license.

Regarding the State's specific concern regarding the licensee's ability to provide offsite

! radiological' effluent monitoring and dose assessmerit, the Commission has previously granted BRP exemption from the emergency preparedness requirements of 10 CFR 50.54(q) and all the requirements in Appendix E to 10 CFR Part 50 in view of the j reduced offsite radiological consequences associated with the current plant status. In

! particular, the staff found that the postulated dose to the general public from any l reasonably conceivable accident would not exceed EPA PAGs and, for a hypothetical

!~ bounding accident (adiabatic heatup of the spent fuel), the length of time available prior to any offsite radiological release givea confidence that mitigative actions and, if necessary, offsite measures for the public could be taken without preplanning. Notwithstanding, I

Consumers continues to monitor radiological effluent release pathways and continues to

.make dose assessments in accordance with regulatory requirements. These monitoring and assessment capabilities are applicable during normal and off-normal conditions and l are subject to NRC inspection and enforcement. On December 17,1998, the state official l

stated that the State of Michigan did not object to the proposed license amendment.

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6.0 ENVIRONMENTAL CONSIDERATION

'The amendment changes the administrative procedures and requirements of the license.

The NRC staff has determinec that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational ,

radiation exposure. The Commission has previously issued a proposed finding that the l amendment involves no significant hazards determination, and there has been no public comment on such finding (62 FR 63974). The State official comments described in Section 5.0 of this Safety Evaluation were not directed to the Commission finding, but

. rather to seeking clarification of the environmental monitoring and offsite dose impact resulting from the licensee-proposed changes as described in the amendment request.

Accordingly, the amendment meets the eligibility criteria for categorical exclusion set fortu in 10 CFR 51.22(c)(9) e d (c)(10). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment. l l

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7.0. .C_ONCLUSION l

' The Comrdssion has concluded, based on the considerations discussed above, thPt (l) there is reast.,nable assurance that the health and safety of the public will not be l

endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment ,

' will not be inimical to the common defense and security or the health and safety of the pablic. {

Principle Contributors: Paul W. Harris i'

Jesse A. Arildsen 4

Michael T. Bugg Stephen P. Klementowicz.

Date: December 24, 1998

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